Legal Opinion

Commissioner of Internal Revenue v. Liberty Bank & Trust Co.

Court of Appeals for the Sixth Circuit

Decided May 12, 1932No. 5780, 5867PublishedCited by 76 opinions

1Opinion of the Court

MOORMAN, Circuit Judge.

Petitions to review decisions of the Board of Tax Appeals by the taxpayer, the Liberty Bank & Trust Company, in No. 5867, and by the Commissioner in No. 5780.

The petitioner in No. 5867 contends that debts owing to it by the Kentucky Wagon Manufacturing Company and the Wolko Lead Batteries Company were recoverable only in part on December 31, 1921, and that deductions should have been allowed therefor from gross income for the year 1921 in the sum of $175,000. The Commissioner disallowed the deductions, and the Board of Tax Appeals sustained his ruling upon the ground…

2Cases cited55 opinions

  1. Osborn v. Bank of United StatesSupreme Court of the United States · 1824
  2. Phillips v. CommissionerSupreme Court of the United States · 1931
  3. Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
  4. Den Ex Dem. Murray v. Hoboken Land & Improvement Co.Supreme Court of the United States · 1856
  5. Fong Yue Ting v. United StatesSupreme Court of the United States · 1893

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3Cited by76 opinions

  1. Ross v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
  2. Manhattan Co. of Virginia, Inc. v. CommissionerUnited States Tax Court · 1968
  3. Joyce v. GentschCourt of Appeals for the Sixth Circuit · 1944
  4. Union Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1940
  5. Portland Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1940

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