Siegel v. Commissioner
United States Board of Tax Appeals
1. A corporation which, after December 31, 1920, in computing its net taxable income deducted individual debts ascertained to be worthless and charged off, may not use its reserve for bad debts in computing its earnings and profits available for dividends, although it had carried on its books such a reserve for many years prior thereto. 2. Irrespective of the method used by the corporation in computing its net income, the Commissioner is sustained in using the charge-off…
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1. A corporation which, after December 31, 1920, in computing its net taxable income deducted individual debts ascertained to be worthless and charged off, may not use its reserve for bad debts in computing its earnings and profits available for dividends, although it had carried on its books such a reserve for many years prior thereto. 2. Irrespective of the method used by the corporation in computing its net income, the Commissioner is sustained in using the charge-off method in computing earnings and profits where it does not appear that the reserve correctly represented the condition of…
1Opinion of the Court
OPINION.
MaRquette:
These proceedings were consolidated for hearing. The following deficiencies in income tax were asserted by the respondent for the year 1923: Benjamin Siegel, $9,669.36; Sophie Siegel, $16,537.22.
The one error asserted in both proceedings is that the respondent, n determining the earnings and profits available for dividends of the Benjamin Siegel Co. (hereinafter referred to as the Company) accumulated since February 28, 1913, failed to deduct therefrom the sum of $63,952, representing net additions to the bad debt reserve shown on the books of that company.
Part of the facts…
2Cases cited7 opinions
- Rock Island, Arkansas & Louisiana Railroad v. United StatesSupreme Court of the United States · 1920
- Stanton v. Baltic Mining Co.Supreme Court of the United States · 1916
- L. S. Ayers & Co. v. CommissionerUnited States Board of Tax Appeals · 1925
- Ayer v. CommissionerUnited States Board of Tax Appeals · 1928
- W. C. Mitchell Co. v. CommissionerUnited States Board of Tax Appeals · 1933
2 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Divine v. CommissionerUnited States Tax Court · 1972
- Luckman v. CommissionerUnited States Tax Court · 1968
- Luckman v. CommissionerUnited States Tax Court · 1971
- Alabama By-Products Corp. v. United StatesDistrict Court, N.D. Alabama · 1955
- Divine v. CommissionerUnited States Tax Court · 1972
3 more not listed; retrieve them via the Exa API.