Avery v. Commissioner
United States Board of Tax Appeals
The amount of bad debts ascertained to be worthless and charged off from the petitioner's books of account in 1919 and deductible from gross income in the petitioner's income-tax return for that year determined.
1Opinion of the Court
*875OPINION.
Smith:
In this appeal we find one of the too frequent examples of the administration of taxing statutes made exceedingly difficult because of irregular and improper bookkeeping practices. From the year 1903 to the year 1919 the petitioner carried on his books a constantly growing and changing account of notes receivable without ever having audited and closed his books in any intervening year. We find that in the year 1919 these unpaid notes included notes owed by something over 100 debtors, which notes the petitioner believed uncollectible on December 31, 1919. A majority of the notes…
2Cited by7 opinions
- Millsap v. CommissionerUnited States Tax Court · 1966
- Heinz v. CommissionerUnited States Board of Tax Appeals · 1933
- American Cigarette & Cigar Co. v. BowersDistrict Court, S.D. New York · 1937
- Avery v. CommissionerUnited States Board of Tax Appeals · 1926
- Hershey v. CommissionerUnited States Tax Court · 1962
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