Schaff v. Commissioner
United States Board of Tax Appeals
1. BAD DEBT DEDUCTION. - Petitioner, a junior partner of a bro kerage firm, handled a trading account for a customer on a discretionary basis, without financial responsibility on his part. In 1929 he departed for Europe and during his absence the so-called stock market crash occurred, resulting in considerable losses in the account.
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1. BAD DEBT DEDUCTION. - Petitioner, a junior partner of a bro kerage firm, handled a trading account for a customer on a discretionary basis, without financial responsibility on his part. In 1929 he departed for Europe and during his absence the so-called stock market crash occurred, resulting in considerable losses in the account. Feeling a moral obligation to the customer for lack of personal attention to the account, he voluntarily guaranteed it and continued to handle it with the hopes of bringing it back to a favorable position. In 1934 petitioner was required to make good his guarantee…
1Opinion of the Court
*645OPINION.
TuRnee :
Petitioner contends that under section 23 (k) of the Revenue Acts of 1934 and 1936 he is entitled to bad debt deductions ' in the amount of $30,195.55 for 1935 and $50,000 for 1936, representing the debts of Marie Campbell Ravelli and Philip Wick, respectively, which debts were ascertained to be worthless in those years. The respondent contends that no debts were due the petitioner from Mrs. Ravelli or Wick and that there was accordingly nothing for petitioner to charge off or deduct as bad debts in the respective years. Respondent contends and petitioner concedes that before…
2Cases cited2 opinions
- Eckert v. BurnetSupreme Court of the United States · 1931
- Lewellyn v. Electric Reduction Co.Supreme Court of the United States · 1927
3Cited by9 opinions
- Proesel v. CommissionerUnited States Tax Court · 1981
- Curran v. CommissionerUnited States Tax Court · 1984
- Dapice v. CommissionerUnited States Tax Court · 1983
- Doyal v. CommissionerUnited States Tax Court · 1978
- Granger v. CommissionerUnited States Tax Court · 1978
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