First Natl. Bank v. Commissioner
United States Tax Court
1. A part of a debt charged off and deducted in 1936 without tax benefit may not be deducted in the taxable year 1939, in the absence of evidence that such part, or any other part, of the debt actually became worthless in 1939. Section 23 (k) (1), Internal Revenue Code, as amended by section 124, Revenue Act of 1942. 2. A contribution made by a taxpayer bank to aid a failing bank which was refunded in part in a later year, may be excluded from taxable income of the year of…
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1. A part of a debt charged off and deducted in 1936 without tax benefit may not be deducted in the taxable year 1939, in the absence of evidence that such part, or any other part, of the debt actually became worthless in 1939. Section 23 (k) (1), Internal Revenue Code, as amended by section 124, Revenue Act of 1942. 2. A contribution made by a taxpayer bank to aid a failing bank which was refunded in part in a later year, may be excluded from taxable income of the year of refund if the taxpayer did not receive a tax benefit, by way of deduction, in the year in which the contribution was made.
1Opinion of the Court
First National Bank, Montoursville, Pennsylvania v. Commissioner.
First Natl. Bank v. Commissioner
Docket No. 109058.
United States Tax Court
1943 Tax Ct. Memo LEXIS 450; 1 T.C.M. (CCH) 602; T.C.M. (RIA) 43079;
February 13, 1943
1. A part of a debt charged off and deducted in 1936 without tax benefit may not be deducted in the taxable year 1939, in the absence of evidence that such part, or any other part, of the debt actually became worthless in 1939. Section 23 (k) (1), Internal Revenue Code, as amended by section 124, Revenue Act of 1942.
2. A contribution made by a taxpayer bank to aid a failing…
2Cases cited9 opinions
- Nat'l Bank of Commerce v. CommissionerUnited States Board of Tax Appeals · 1939
- Central Loan & Inv. Co. v. CommissionerUnited States Board of Tax Appeals · 1939
- First Nat'l Bank v. CommissionerUnited States Tax Court · 1942
- Gaylord v. CommissionerUnited States Board of Tax Appeals · 1940
- Collins v. CommissionerUnited States Board of Tax Appeals · 1942
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