Boissevain v. Commissioner
United States Tax Court
Deductions from Income -- Bad Debts -- Nonbusiness Debts -- Section 23 (k) (4). -- On the facts, held, that a debt of a corporation to the petitioner which became worthless in 1944 is a "non-business debt" under section 23 (k) (4) of the Code.
1Opinion of the Court
OPINION.
HaReon, Judge:
The only issue is whether the loss sustained in 1944 by the petitioner from the worthlessness of the debt of the Double Arrow Ranch corporation shall be considered a loss from the sale or exchange in 1944 of a capital asset held for not more than six months under the provisions of section 23 (k) (4) of the Internal Revenue Code,1 as the respondent has determined; or whether the loss is one from a worthless debt which comes within the scope of section 23 (k) (l),1 as amended by section 23 (k) (4), so as to be deductible in the entire amount of the loss, as the petitioner…
2Cases cited15 opinions
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3Cited by93 opinions
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