H. H. Brown Co. v. Commissioner
United States Board of Tax Appeals
1. Percentages of certain debts held properly deductible as worthless in the year 1922. 2. Massachusetts state and town taxes which become a liability and accrued within a fiscal year are allowable deductions from gross income in such year.
1Opinion of the Court
*115OPINION.
Millieen:
The first issue relates to the five accounts appearing on petitioner’s books at June 30, 1922, totaling $16,197.03 and upon which a deduction of $12,149.45 is claimed. The action of the president of petitioner in charging off on the books of account the percentages recited in the findings of fact was based upon his detailed knowledge with respect to each account. The ascertainment of the worthlessness of a debt, either in whole or in part, is the exercise of sound business judgment based upon as complete information as is practicably obtainable. The president of petitioner,…
2Cases cited7 opinions
- Richardson v. City of BostonMassachusetts Supreme Judicial Court · 1889
- Jennings v. CollinsMassachusetts Supreme Judicial Court · 1868
- Springdale Finishing Co. v. CommonwealthMassachusetts Supreme Judicial Court · 1922
- Cochran v. GuildMassachusetts Supreme Judicial Court · 1870
- Rogers v. GookinMassachusetts Supreme Judicial Court · 1908
2 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Abramson v. CommissionerUnited States Tax Court · 1986
- Pardee v. CommissionerUnited States Tax Court · 1967
- Simon J. Murphy Company and Social Research Foundation, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
- Missouri State Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Koebig & Koebig, Inc. v. CommissionerUnited States Tax Court · 1964
22 more not listed; retrieve them via the Exa API.