Collin v. Commissioner
United States Board of Tax Appeals
A taxpayer who keeps his accounts on a cash receipts and disbursements basis may not deduct from gross income, as for a bad debt, an item of accrued interest which he had not at any time previously treated as income or reported as taxable income.
1Opinion of the Court
*306OPINION.
Korner :
The issue involved in this appeal is simply stated. It is: May a taxpayer who keeps his accounts on a cash receipts and disbursements basis deduct from gross income, as for a bad debt, accrued interest which he had not at any time previously treated as taxable income ?
The taxpayer insists that section 214(a) (7) of the Revenue Act of 1918 authorized such deduction. That section reads as follows:
Sec. 214(a). That in computing net income there shall be allowed as deductions: * * * (7) Debts ascertained to be worthless and charged oft within the taxable year.
The contention of the…
2Cases cited4 opinions
- United States v. MerriamSupreme Court of the United States · 1923
- Cornell v. CoyneSupreme Court of the United States · 1904
- Swan & Finch Co. v. United StatesSupreme Court of the United States · 1903
- Plant v. WalshDistrict Court, D. Connecticut · 1922
3Cited by25 opinions
- Gertz v. CommissionerUnited States Tax Court · 1975
- Alsop v. CommissionerUnited States Tax Court · 1960
- District Bond Co. v. CommissionerCourt of Appeals for the Ninth Circuit · 1940
- Fed. Home Loan Mortg. Corp. v. Comm'rUnited States Tax Court · 2003
- Tiscornia v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1938
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