Legal Opinion

Findley v. Commissioner

United States Tax Court

Decided November 29, 1955No. Docket No. 40572Published

Petitioner entered into a contract for the strip mining of coal, under which he advanced moneys to contractors for payroll and other operating expenses. He canceled the contract in April 1949; and he thereafter charged off part of the advances and claimed a partial bad debt deduction for the same in his 1948 return.

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Petitioner entered into a contract for the strip mining of coal, under which he advanced moneys to contractors for payroll and other operating expenses. He canceled the contract in April 1949; and he thereafter charged off part of the advances and claimed a partial bad debt deduction for the same in his 1948 return. Held, respondent did not err in disallowing the partial bad debt deduction for 1948, since in that year there was no change in the contractors' ability to repay the advances in the manner provided in the contract and no abandonment or charge-off of any part of the obligation as an…

1Opinion of the Court

H. W. Findley and Helen B. Findley, Petitioners, v. Commissioner of Internal Revenue, Respondent

Findley v. Commissioner

Docket No. 40572

United States Tax Court

25 T.C. 311; 1955 U.S. Tax Ct. LEXIS 42;

November 29, 1955, Filed

Decision will be entered under Rule 50.

Petitioner entered into a contract for the strip mining of coal, under which he advanced moneys to contractors for payroll and other operating expenses. He canceled the contract in April 1949; and he thereafter charged off part of the advances and claimed a partial bad debt deduction for the same in his 1948 return. Held, respondent did…

2Cases cited1 opinion

  1. Findley v. CommissionerUnited States Tax Court · 1955

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