Home Agency Co. v. Commissioner
United States Tax Court
Held: (1) That the first note of a former employee, K, evidencing indebtedness to petitioner, had value at the beginning of 1961, but became worthless in 1961. (2) That a second note of the same employee had value on January 1, 1961, but did not become worthless in 1961 because J had a legal liability as the co-maker thereof, and petitioner failed to prove that its claim against J had no value in 1961. (3) That the loss in 1961 from the worthless note and indebtedness of K…
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Held: (1) That the first note of a former employee, K, evidencing indebtedness to petitioner, had value at the beginning of 1961, but became worthless in 1961. (2) That a second note of the same employee had value on January 1, 1961, but did not become worthless in 1961 because J had a legal liability as the co-maker thereof, and petitioner failed to prove that its claim against J had no value in 1961. (3) That the loss in 1961 from the worthless note and indebtedness of K was $32,514.50, which is deductible in 1961 under section 166(a)(1), 1954 Code. (4) That petitioner sustained a net…
1Opinion of the Court
The Home Agency Company v. Commissioner.
Home Agency Co. v. Commissioner
Docket No. 4105-64.
United States Tax Court
T.C. Memo 1966-48; 1966 Tax Ct. Memo LEXIS 234; 25 T.C.M. (CCH) 272; T.C.M. (RIA) 66048;
March 9, 1966
Held: (1) That the first note of a former employee, K, evidencing indebtedness to petitioner, had value at the beginning of 1961, but became worthless in 1961. (2) That a second note of the same employee had value on January 1, 1961, but did not become worthless in 1961 because J had a legal liability as the co-maker thereof, and petitioner failed to prove that its claim against J…
2Cases cited13 opinions
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Frentz v. CommissionerUnited States Tax Court · 1965
- George M. Still, Inc. v. CommissionerUnited States Tax Court · 1953
- Geo. M. Still, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1955
- Minneapolis, St. Paul & Sault Ste. Marie Railroad v. United StatesUnited States Court of Claims · 1964
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