Legal Opinion

Citizens Trust Co. v. Commissioner

United States Board of Tax Appeals

Decided November 6, 1925No. Docket No. 3373Published

1. The taxpayer held notes and other obligations of an individual who became bankrupt in 1919 and who just prior thereto delivered certain insurance policies as additional security.

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1. The taxpayer held notes and other obligations of an individual who became bankrupt in 1919 and who just prior thereto delivered certain insurance policies as additional security. The bankrupt's estate was finally settled and closed in 1920. Held, that the taxpayer sustained a deductible loss in 1920 of the difference between its claim and the sum of the amounts of the dividend in bankruptcy and the cash-surrender value of the insurance policies at the time they were surrendered. 2. Among the furniture, fixtures, and equipment belonging to the taxpayer, were typewriters, adding and…

1Opinion of the Court

APPEAL OF CITIZENS TRUST CO. OF UTICA.

Citizens Trust Co. v. Commissioner

Docket No. 3373.

United States Board of Tax Appeals

2 B.T.A. 1239; 1925 BTA LEXIS 2132;

November 6, 1925, Decided Submitted July 10, 1925.

1. The taxpayer held notes and other obligations of an individual who became bankrupt in 1919 and who just prior thereto delivered certain insurance policies as additional security. The bankrupt's estate was finally settled and closed in 1920. Held, that the taxpayer sustained a deductible loss in 1920 of the difference between its claim and the sum of the amounts of the dividend in…

2Cases cited1 opinion

  1. Appeal of Citizens Trust Co. of UticaUnited States Board of Tax Appeals · 1925

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