Legal Opinion
International Proprietaries, Inc. v. Commissioner
United States Tax Court
Decided April 28, 1952No. Docket No. 26230PublishedCited by 1 opinion
Deduction for partially worthless debts disallowed for failure to charge off specific debts.
1Opinion of the Court
OPINION.
Artjndell, Judge:
The sole question before us is whether the Commissioner abused his discretion in disallowing a partially worthless debt deduction in the amount of $7,500 claimed by the petitioner for the taxable year 1946. Section 23 (k) (1), Internal Revenue Code.
Section 23 (k) (1), the statutory provision relied on by the petitioner, allows deductions for worthless debts and, in addition, permits deductions for partially worthless debts in language worded as follows: “* * * and when satisfied that a debt is recoverable only in part, the Commissioner may allow such debt, in an…
2Cases cited5 opinions
- Stranahan v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1930
- Wilson Bros. & Co. v. CommissionerCourt of Appeals for the Ninth Circuit · 1941
- Capital Nat'l Bank v. CommissionerUnited States Tax Court · 1951
- E. Richard Meinig Co. v. CommissionerUnited States Tax Court · 1947
- Malden Trust Co. v. CommissionerCourt of Appeals for the First Circuit · 1940
3Cited by1 opinion
- International Proprietaries, Inc. v. CommissionerUnited States Tax Court · 1952