Hawkins v. Commissioner
United States Tax Court
The alleged indebtedness in the sum of $ 26,389.65 advanced by petitioner to a corporation of which he was a stockholder and officer was not wholly worthless as of the close of the taxable year 1943, and was consequently not the subject of a bad debt deduction under section 23(k)(1), Internal Revenue Code. Nor did $ 1,509.05 of such sum constitute an ordinary and necessary expense of petitioner.
1Opinion of the Court
OPINION.
Bruce, Judge:
Petitioner’s first contention is that the deduction taken of $26,389.65 represents a business bad debt which became wholly worthless during the calendar year 1943. By amended petition he contends that if the deduction does not represent a business bad debt, the $1,509.05 expended by him as travel expenses on behalf of Buffalo is allowable as an ordinary and necessary expense in the operation of petitioner’s business conducted as James M. Hawkins Company, incurred in efforts made by such business to procure an essential supply of brick for its customers.
Respondent contends…
2Cases cited2 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Coleman v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1936
3Cited by16 opinions
- Riss v. CommissionerUnited States Tax Court · 1971
- Perry v. CommissionerUnited States Tax Court · 1954
- Gilman v. CommissionerUnited States Tax Court · 1979
- Hunt v. CommissionerUnited States Tax Court · 1989
- Gladstone v. CommissionerUnited States Tax Court · 1990
11 more not listed; retrieve them via the Exa API.