Campbell v. Commissioner
United States Tax Court
Deductions -- Bad Debts -- Business or Nonbusiness -- Section 23 (k). -- Loans which became worthless were business bad debts rather than nonbusiness bad debts where made by individuals to one of a number of corporations which they had organized and which they owned and operated.
1Opinion of the Court
OPINION.
Mttbdock, Judge:
The Commissioner in his brief attempts to argue matters inconsistent with his own determination as disclosed in the deficiency notices. He may not do that under the rules of the Court without affirmative pleadings on his part. It must be recognized, for the purpose of this proceeding, that the petitioners actually loaned the money to the Campbell Bros. Coal Co. of Akron, in the amounts claimed in their returns, and those amounts became worthless during 1944, because those facts are not only consistent with, but are essential to, the determination made by the…
2Cases cited1 opinion
- Sic v. CommissionerUnited States Tax Court · 1948
3Cited by102 opinions
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Millsap v. CommissionerUnited States Tax Court · 1966
- Boissevain v. CommissionerUnited States Tax Court · 1951
- Towers v. CommissionerUnited States Tax Court · 1955
- Smith v. CommissionerUnited States Tax Court · 1951
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