Sass v. Commissioner
United States Board of Tax Appeals
Loss. - In 1919 a bank called upon petitioner to pay $24,153.12 as guarantor for certain loans and in that year petitioner paid $4,899.58 cash and gave his note for the balance. Petitioner was on the cash basis. Held, that the $4,899.58 is a proper deduction and that the amount of the note is not deductible as a loss sustained in 1919. 7 B.T.A. 557 modified.
1Opinion of the Court
*157OPINION.
Trttsstct.t, :
The only issue raised in this proceeding is whether petitioner is entitled to a deduction as a loss in 1919 of the amount of $24,153.12 which he was called upon by the bank to pay as guarantor of certain loans made by the bank through the efforts of petitioner.
The definition of the noun “ loss ” as given in Webster’s Dictionary is, “Act or fact of suffering deprivation; failure to keep a posses*158sion; esp., the unintentional parting with something of value; * * See also the cases of Hawaiian Commercial & Sugar Co., Ltd. v. Tax Assessor, 14 Hawaii, 601, and Queenan v.…
2Cases cited2 opinions
- Queenan v. PalmerIllinois Supreme Court · 1886
- Hawaiian Commercial & Sugar Co. v. Tax Assessor & CollectorHawaii Supreme Court · 1903
3Cited by2 opinions
- Schlemmer v. United StatesCourt of Appeals for the Second Circuit · 1938
- Sass v. CommissionerUnited States Board of Tax Appeals · 1928