Murchison Nat'l Bank v. Commissioner
United States Board of Tax Appeals
Under section 234(a)(5) of the Revenue Act of 1918, a part of a debt may not be written off as worthless and the other part maintained on the books of taxpayer as having a value. (Appeal of Steele Cotton Mill Company,1 B.T.A. 299.) A taxpayer holding collateral security for the payment of a debt may not write off as worthless, under section 234(a)(5) of the Revenue Act of 1918, the difference between the amount of the debt and the estimated value of the security.
1Opinion of the Court
*619OPINION.
Marquette :
The Commissioner filed a plea in bar to the right of taxpayer to maintain its appeal with respect to the assignments of error set forth in paragraphs 4 (a) and (c) of the petition, and alleged therein “that the facts stated in paragraphs 5 (a), (b), and (d) are not sufficient to sustain the said alleged errors referred to in paragraphs 4 (a) and (c).” At the hearing, the Commissioner, by his attorney, admitted as true, both for the purpose of the plea in bar and for decision of the appeal on its merits, the facts alleged in paragraphs 5 (a), (b), and (c) of the petition. In…
2Cited by6 opinions
- First Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1928
- Midland Nat'l Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Murchison Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1925
- South Hills Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Stern v. CommissionerUnited States Board of Tax Appeals · 1926
1 more not listed; retrieve them via the Exa API.