Bart v. Commissioner
United States Tax Court
Deduction From Income -- Bad Debts -- Business v. Nonbusiness -- Sec. 23 (k) (1) and (4), I. R. C. -- A bad debt resulting from advances by an advertising agent to a client in the course of business of assisting in the publication of a magazine was proximately related to the advertising agency business and was deductible as a business bad debt.
1Opinion of the Court
OPINION.
MuRdock, Judge:
Stuart, as sole proprietor, was engaged in business as an advertising agent when the debt arose and when it became worthless. One of his clients was Physicians Publication, Inc., which employed him as an advertising agent in connection with the publication of its magazine. Through that client relationship he obtained other clients, some of whom .advertised in the magazine. He ordered printing arid made other coriimitments for Physicians Publication, Inc., in the course of his business. He had to advance money to the client to enable it to pay those and other operating…
2Cases cited1 opinion
- Cluett v. CommissionerUnited States Tax Court · 1947
3Cited by58 opinions
- John M. Trent and Lisa M. Trent v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
- Steadman v. Comm'rUnited States Tax Court · 1968
- Nash v. CommissionerUnited States Tax Court · 1958
- Martin v. CommissionerUnited States Tax Court · 1955
- Estate of Byers v. CommissionerUnited States Tax Court · 1972
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