Appeal of Cherry Basset Co.

*428OPINION.

Ivins:

It appears from testimony of the taxpayer’s xvitnesses that it was the custom of the concern in regard to the collectibility of accounts to “never consider anything good if we felt doubtful about it,” and in charging off as bad debts the accounts involved in this appeal that custom would seem to be the determining factor.

We are not convinced that the accounts involved were ascertained to be worthless, or that they were in fact worthless when charged off.

The Board held in the Appeal of Steele Cotton Mill Co., 1 B. T. A. 299, that under the Revenue Act of 1918 part of a debt may…