Gertz v. Commissioner
United States Tax Court
Petitioner claimed a bad debt deduction under sec. 166 for wages never paid. Held, respondent did not err is disallowing the bad debt deduction since petitioner had never reported the amount claimed in income, as required by sec. 1.166-1(e), Income Tax Regs.Held, further, petitioner is not entitled to claim a tax credit for wages his employer was never liable to withhold.
1Opinion of the Court
Robert L. Gertz and J. Kay Gertz, Petitioners v. Commissioner of Internal Revenue, Respondent
Gertz v. Commissioner
Docket No. 307-73
United States Tax Court
64 T.C. 598; 1975 U.S. Tax Ct. LEXIS 108;
July 21, 1975, Filed
Decision will be entered under Rule 155.
Petitioner claimed a bad debt deduction under sec. 166 for wages never paid. Held, respondent did not err is disallowing the bad debt deduction since petitioner had never reported the amount claimed in income, as required by sec. 1.166-1(e), Income Tax Regs.Held, further, petitioner is not entitled to claim a tax credit for wages his employer…
2Cases cited6 opinions
- Bush Terminal Bldgs. Co. v. CommissionerUnited States Tax Court · 1946
- United States v. FogartyCourt of Appeals for the Eighth Circuit · 1947
- Gertz v. CommissionerUnited States Tax Court · 1975
- Collin v. CommissionerUnited States Board of Tax Appeals · 1925
- Simons v. CommissionerUnited States Board of Tax Appeals · 1925
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