Stewart v. Commissioner
United States Board of Tax Appeals
Where indebtedness under a land sale contract was settled for less than its face amount, which was its cost, the holder accepting bonds of the Federal Farm Mortgage Corporation and cash, conveying the legal title to the purchaser and canceling the remainder of the debt, which was worthless, held that his loss is deductible in full as a bad debt, and is not limited by the capital loss provisions affecting sales or exchanges of property. Sec. 117, Revenue Act of 1934.
1Opinion of the Court
JAMES R. STEWART, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Stewart v. Commissioner
Docket No. 89950.
United States Board of Tax Appeals
39 B.T.A. 87; 1939 BTA LEXIS 1073;
January 12, 1939, Promulgated
Where indebtedness under a land sale contract was settled for less than its face amount, which was its cost, the holder accepting bonds of the Federal Farm Mortgage Corporation and cash, conveying the legal title to the purchaser and canceling the remainder of the debt, which was worthless, held that his loss is deductible in full as a bad debt, and is not limited by the capital…
2Cases cited13 opinions
- Watson v. CommissionerUnited States Board of Tax Appeals · 1932
- Woodward v. McCollumNorth Dakota Supreme Court · 1907
- Rogers v. CommissionerUnited States Board of Tax Appeals · 1938
- Roby v. Bismarck National BankNorth Dakota Supreme Court · 1894
- Hale v. CommissionerUnited States Board of Tax Appeals · 1935
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