Fowler Bros. & Cox, Inc. v. Commissioner of Internal Revenue

McAllister, circuit judge.

Petitioner appeals from the decision of the Board of Tax Appeals (now the Tax Court of the United States), which denied deductions claimed on income tax return for a bad debt, payment of salaries, and dividends.

Deduction for Bad Debt

The alleged worthless debt consisted of a deposit in a closed bank; but petitioner owed to the bank, on promissory note, at least as much as the deposit. Petitioner for several years was attempting to offset the note by the deposit, but up to and including the tax year, the determination of the question was in abeyance. Petitioner,…