Legal Opinion

Sass v. Commissioner

United States Board of Tax Appeals

Decided May 28, 1928No. Docket No. 6922Published

Loss. - In 1919 a bank called upon petitioner to pay $24,153.12 as guarantor for certain loans and in that year petitioner paid $4,899.58 cash and gave his note for the balance. Petitioner was on the cash basis. Held, that the $4,899.58 is a proper deduction and that the amount of the note is not deductible as a loss sustained in 1919. 7 B.T.A. 557 modified.

1Opinion of the Court

MORRIS SASS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Sass v. Commissioner

Docket No. 6922.

United States Board of Tax Appeals

12 B.T.A. 156; 1928 BTA LEXIS 3584;

May 28, 1928, Promulgated

Loss. - In 1919 a bank called upon petitioner to pay $24,153.12 as guarantor for certain loans and in that year petitioner paid $4,899.58 cash and gave his note for the balance. Petitioner was on the cash basis. Held, that the $4,899.58 is a proper deduction and that the amount of the note is not deductible as a loss sustained in 1919. 7 B.T.A. 557 modified.

Thos. J. Reilly, Esq., and Robert…

2Cases cited5 opinions

  1. Queenan v. PalmerIllinois Supreme Court · 1886
  2. Hawaiian Commercial & Sugar Co. v. Tax Assessor & CollectorHawaii Supreme Court · 1903
  3. Davis v. CommissionerUnited States Board of Tax Appeals · 1927
  4. Sass v. CommissionerUnited States Board of Tax Appeals · 1927
  5. Sass v. CommissionerUnited States Board of Tax Appeals · 1928

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