Heinz v. Commissioner
United States Board of Tax Appeals
1. Where all essential facts indicating worthlessness of a debt were known to the petitioner in 1927, he is not entitled to charge off the debt and deduct the amount thereof from gross income for 1928. 2. On February 26, 1929, petitioner received a check for $4,391.60 from a syndicate of which he was a member, which amount represented "interest and dividend adjustments," and was the final distribution of profits upon termination of the syndicate's operations.
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1. Where all essential facts indicating worthlessness of a debt were known to the petitioner in 1927, he is not entitled to charge off the debt and deduct the amount thereof from gross income for 1928. 2. On February 26, 1929, petitioner received a check for $4,391.60 from a syndicate of which he was a member, which amount represented "interest and dividend adjustments," and was the final distribution of profits upon termination of the syndicate's operations. All events which fixed the amount of petitioner's distributive share of the syndicate's profits had transpired on or before November…
1Opinion of the Court
*279OPINION.
Trammell :
Issue 1. — The petitioner loaned the sum of $5,000 to the Piedmont Hotel Operating Co. on December 22, 1927, for the purpose of paying taxes of said company. Each of petitioner’s associates advanced a like sum for the same purpose, under the circumstances set out in our findings of fact above. Petitioner alleges that in 1928 he ascertained that this debt was worthless, charged it off and subsequently claimed a deduction therefor in his return for 1928. The respondent disallowed said deduction on the ground that the debt became worthless in the prior year, 1927.
It is not…
2Cases cited7 opinions
- Beaumont v. CommissionerUnited States Board of Tax Appeals · 1932
- Stewart v. CommissionerUnited States Board of Tax Appeals · 1929
- Snyder v. CommissionerUnited States Board of Tax Appeals · 1930
- Cross v. CommissionerUnited States Board of Tax Appeals · 1930
- Avery v. CommissionerUnited States Board of Tax Appeals · 1926
2 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- James A. Messer Co. v. CommissionerUnited States Tax Court · 1972
- Lewis v. CommissionerUnited States Board of Tax Appeals · 1934
- Miller v. CommissionerUnited States Board of Tax Appeals · 1934
- Neville v. CommissionerUnited States Board of Tax Appeals · 1933
- Heinz v. CommissionerUnited States Board of Tax Appeals · 1933
1 more not listed; retrieve them via the Exa API.