Legal Opinion
George T. Smith and Clela v. Smith v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided December 7, 1966No. 16632PublishedCited by 44 opinions
1Opinion of the Court
PECK, Circuit Judge.
The respondent having declared a deficiency to be due on the petitioners’ * Federal Income Tax Return for the year 1957, this action was filed to prevent its collection. In that return, a deduction for alleged bad debts claimed to have become worthless during the taxable year was claimed under the provisions of 26 U.S.C. § 166. Subparagraph (a) (1) provides for the deduction of any debt becoming worthless within the taxable year, but subparagraph (d) (1) (A) makes the former section inapplicable to non-business debts in the case of a taxpayer other than a corporation; the…
2Cases cited13 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Whipple v. CommissionerSupreme Court of the United States · 1963
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
8 more not listed; retrieve them via the Exa API.
3Cited by44 opinions
- Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
- Roth Steel Tube Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1986
- In the Matter of Uneco, Inc., Bankrupt. United States of America v. Uneco, Inc.Court of Appeals for the Eighth Circuit · 1976
- Jack P, Stanton and Virginia G. Stanton v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- United States v. John William Gotcher Et Ux.Court of Appeals for the Fifth Circuit · 1968
39 more not listed; retrieve them via the Exa API.