Legal Opinion

First Nat'l Bank v. Commissioner

United States Board of Tax Appeals

Decided January 19, 1928No. Docket No. 11745Published

The decline in the value of Imperial Russian Government bonds acquired by petitioner as an investment which were not sold or otherwise disposed of during the taxable year may not be deducted as a bad debt uncollectible in part under the provisions of section 234(a)(5) of the Revenue Act of 1921. Since the bonds have not been shown to have been worthless at the end of the taxable year 1921, petitioner is not entitled to a deduction of the cost thereof as a loss sustained.

1Opinion of the Court

FIRST NATIONAL BANK OF ST. PAUL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

First Nat'l Bank v. Commissioner

Docket No. 11745.

United States Board of Tax Appeals

10 B.T.A. 32; 1928 BTA LEXIS 4220;

January 19, 1928, Promulgated

The decline in the value of Imperial Russian Government bonds acquired by petitioner as an investment which were not sold or otherwise disposed of during the taxable year may not be deducted as a bad debt uncollectible in part under the provisions of section 234(a)(5) of the Revenue Act of 1921. Since the bonds have not been shown to have been worthless at…

2Cases cited8 opinions

  1. United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
  2. Lewellyn v. Electric Reduction Co.Supreme Court of the United States · 1927
  3. New York Life Insurance v. EdwardsSupreme Court of the United States · 1926
  4. Corn Exchange Bank v. CommissionerUnited States Board of Tax Appeals · 1927
  5. Stern v. CommissionerUnited States Board of Tax Appeals · 1926

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