Industrial Trust Co. v. Commissioner
United States Tax Court
In 1929 the petitioner made a secured loan to a corporation that became insolvent later in that year and went out of existence in 1933. Prior to 1943 the petitioner acquired ownership of the property it had received as security for the debt. In 1943 the petitioner claimed a worthless debt deduction. Held, the debt became worthless prior to 1943 and the deduction is not allowable for that year. Section 23 (k) (1), Internal Revenue Code.
1Opinion of the Court
Industrial Trust Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Industrial Trust Co. v. Commissioner
Docket No. 28866
United States Tax Court
18 T.C. 198; 1952 U.S. Tax Ct. LEXIS 206;
May 7, 1952, Promulgated
Decision will be entered under Rule 50.
In 1929 the petitioner made a secured loan to a corporation that became insolvent later in that year and went out of existence in 1933. Prior to 1943 the petitioner acquired ownership of the property it had received as security for the debt. In 1943 the petitioner claimed a worthless debt deduction. Held, the debt became worthless…
2Cases cited4 opinions
- Old Colony Trust Associates v. HassettCourt of Appeals for the First Circuit · 1945
- Le Roy v. CommissionerUnited States Tax Court · 1944
- Commissioner of Internal Revenue v. RoyCourt of Appeals for the Second Circuit · 1945
- Industrial Trust Co. v. CommissionerUnited States Tax Court · 1952