Hoffman v. Commissioner
United States Board of Tax Appeals
The amount which a decedent owed to another at the time of his death is not deductible by his estate from its income when paid.
1Opinion of the Court
OPINION.
Murdock:
The Commissioner determined a deficiency of $3,44^92 in the income tax of the estate for the year 1930. The issue for decision is whether the estate is entitled to a deduction of $94,344.21 claimed on the return as a bad debt. The facts have been stipulated as follows:
Jacob S. Hoffman died testate, a resident of Chicago, Cook County, Illinois, on January 17, 1930, and petitioner, Harry I. Hoffman, is the duly qualified and acting Executor of the Estate of said decedent.
Prior to his death the decedent and another were co-guarantors of the obligations of a third party and were…
2Cited by7 opinions
- Sletteland v. CommissionerUnited States Tax Court · 1965
- Sanburn v. United StatesDistrict Court, D. Massachusetts · 1947
- Gallagher v. CommissionerUnited States Tax Court · 1944
- Hoffman v. CommissionerUnited States Board of Tax Appeals · 1937
- Kirsch v. CommissionerUnited States Tax Court · 1985
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