Mather v. Commissioner
United States Tax Court
Petitioners were residuary legatees. The testator had executed a note jointly with and as an accommodation to another. The note was allowed as a claim against testator's estate which was thereafter distributed in kind subject to estate liabilities. The accommodated party was insolvent at the date of testator's death and has been so ever since.
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Petitioners were residuary legatees. The testator had executed a note jointly with and as an accommodation to another. The note was allowed as a claim against testator's estate which was thereafter distributed in kind subject to estate liabilities. The accommodated party was insolvent at the date of testator's death and has been so ever since. Petitioners made payments on the joint note in 1939. Held, that petitioners are not entitled to bad debt deductions under Section 23 (k) of the Internal Revenue Code.
1Opinion of the Court
S. Livingston Mather, Testamentary Trust u/w of Samuel Mather, Deceased, William G. Mather and S. Livingston Mather, Trustees v. Commissioner.
Mather v. Commissioner
Docket Nos. 789, 790.
United States Tax Court
1944 Tax Ct. Memo LEXIS 175; 3 T.C.M. (CCH) 729; T.C.M. (RIA) 44237;
July 20, 1944
Petitioners were residuary legatees. The testator had executed a note jointly with and as an accommodation to another. The note was allowed as a claim against testator's estate which was thereafter distributed in kind subject to estate liabilities. The accommodated party was insolvent at the date of…
2Cases cited8 opinions
- Young Men's Christian Ass'n v. DavisOhio Supreme Court · 1922
- Robinson v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1931
- Kleberg v. CommissionerUnited States Board of Tax Appeals · 1934
- O'Neil v. CommissionerUnited States Board of Tax Appeals · 1934
- Bennett v. CommissionerUnited States Board of Tax Appeals · 1939
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