First State Bank v. United States

*335MEMORANDUM BY THE COURT

It appears from the agreed statement of facts that in the year 1919, the plaintiff held certain bonds in the amount of $6,000.00, which the commissioner admits to have then had no market value, and were in fact worthless as shown by the result of subsequent endeavors to realize something upon them.

The controversy in the case is as to whether plaintiff should have been allowed a deduction of $6,000.00 for bad debts on account of these bonds in its income-tax return for 1919. There is no dispute but that they were worthless. The principal contention on behalf of the…