Dominion Nat'l Bank v. Commissioner
United States Board of Tax Appeals
1. In 1928 petitioner held policies of insurance on the lives of its debtors, which policies had a greater face value but a lower cash surrender value than the amount of the debts. In that year it was determined that the debts were uncollectible from the debtors.
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1. In 1928 petitioner held policies of insurance on the lives of its debtors, which policies had a greater face value but a lower cash surrender value than the amount of the debts. In that year it was determined that the debts were uncollectible from the debtors. Held that petitioner may deduct, as a debt ascertained to be worthless and charged off in part, the difference between the amount of the debts and the cash surrender value of the policies, even though it still holds the policies. 2. Held, further, that petitioner may deduct as a business expense the premiums paid on the insurance…
1Opinion of the Court
*422OPINION.
A bttndet.t. :
There is some difference between the parties as to the cash surrender value of the Smith brothers’ policies and the amount of the annual premiums. The following brief description of the policies is taken from the testimony of petitioner’s president and indicates how we arrived at the amounts set out in the findings of fact:
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Petitioner now concedes that it is not entitled to a bad debt deduction on account of the Smith brothers’ indebtedness of more than the difference between the cash.surrender value of the policies in 1928 and the amount of the debt charged…
2Cases cited1 opinion
- First National Bank v. Terry's Adm'rSupreme Court of Virginia · 1901
3Cited by8 opinions
- Commissioner of Internal Revenue v. The Charleston Nat. Bank, Charleston, W. VaCourt of Appeals for the Fourth Circuit · 1954
- First Nat. Bank & Trust Co. of Tulsa v. JonesCourt of Appeals for the Tenth Circuit · 1944
- Donald B. Jones & Mercy P. Jones v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1956
- First Nat. Bank & Trust Co. v. JonesDistrict Court, W.D. Oklahoma · 1943
- Meyer v. United StatesDistrict Court, S.D. New York · 1948
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