Sooy v. Commissioner
United States Board of Tax Appeals
1. Money advanced by one brother to another with the understanding and expectation of both that repayment would be made held to be a loan and not a gift. 2. Where the borrower was in ill health at the time the loan was made and died without repaying it, leaving no estate from which collection could be made, held, the amount of such loan is properly deductible as a bad debt for the year in which it was ascertained to be worthless and written off.
1Opinion of the Court
CHARLES H. SOOY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Sooy v. Commissioner
Docket No. 2882.
United States Board of Tax Appeals
10 B.T.A. 493; 1928 BTA LEXIS 4098;
February 2, 1928, Promulgated
1. Money advanced by one brother to another with the understanding and expectation of both that repayment would be made held to be a loan and not a gift.
2. Where the borrower was in ill health at the time the loan was made and died without repaying it, leaving no estate from which collection could be made, held, the amount of such loan is properly deductible as a bad debt for the year…
2Cases cited1 opinion
- Sooy v. CommissionerUnited States Board of Tax Appeals · 1928