Avery v. Commissioner of Internal Revenue

FOSTER, Circuit Judge.

This is a petition for review of a decision of the United States Board of Tax Appeals.

Petitioner, Thomas J. Avery, an inhabitant of Georgia, in filing his income tax return for 1919, claimed as a deduction the sum of $36,567.28 for debts ascertained to be worthless and charged off during that taxable year. The Commissioner of Internal Revenue, respondent, allowed a deduction of only $1,841.26 and determined a deficiency of taxes amounting to $15,335.65. On appeal the board, allowed an additional deduction of $392.96, determined that the other worthless accounts charged…