Bank of Newberry v. Commissioner
United States Tax Court
1. Income. -- Recovery on bad debt, deducted in prior year without reduction of petitioner's tax for such prior year, held, not taxable income.
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1. Income. -- Recovery on bad debt, deducted in prior year without reduction of petitioner's tax for such prior year, held, not taxable income. Citizens State Bank, 46 B.T.A. 964; sec. 22 (b), Internal Revenue Code, as amended by sec. 116 of the 1942 Act. 2. Deduction -- Bad Debt. -- Petitioner claimed a partially worthless bad debt deduction in a prior net loss year and in the subsequent taxable year, when the remaining balance of the debt became worthless, it claimed a deduction of not only such balance but also the amount deducted in the prior year. Held, that the amount properly deducted…
1Opinion of the Court
OPINION.
Tyson, Judge:
This proceeding involves an income tax deficiency of ipJ ,101.74 for the calendar year 1939.
The petitioner assigns error in the respondent’s determination which increased its income as reported by a total of $6,987, resulting from (1) the inclusion in income of two items, namely, $200 and $27, as the respective.recoveries in the taxable year on bad debts charged off and deducted in prior years in which petitioner sustained net losses; (2) the disallowance of a claimed bad debt deduction of $480, which amount was charged off and deducted in a prior year in which petitioner…
2Cited by13 opinions
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- Robinson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1950
- Fairbanks, Morse & Co. v. HarrisonDistrict Court, N.D. Illinois · 1945
- Exchange State Bank v. CommissionerUnited States Tax Court · 1947
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