In re Assessment of Taxes, First American Sayings & Trust Co. of Hawaii

OPINION OF THE COURT BY

FREAR, C.J.

These are appeals under the income tax law.

The assessor appeals in all these cases from decisions of the *503Tax Appeal Court allowing certain deductions — mostly of bad ■ debts. He contends that only losses of income as distinguished from losses of capital may be deducted and only such losses as • have occurred during the year in question, and that in these cases • the losses were in general losses of capital and occurred before - the year. The statute is somewhat involved and not altogether' clear. It is somewhat arbitrary in its provisions. Statutes in…