Pate v. Commissioner
United States Board of Tax Appeals
Held that certain accounts claimed as deductions for bad debts have been included in income for prior years and certain other accounts were ascertained to be worthless and charged off in the taxable year.
1Opinion of the Court
*1237OPINION.
Gbeen :
It has been stipulated by the parties hereto that of the $63,580.72 alleged as bad debts, $30,000 became worthless prior to the taxable year 1922.
*1238Two questions are at issue: (1) As to whether or not the debts ascertained to be worthless during the taxable year had been previously reported as income, and (2) as to whether or not the debts ascertained to be worthless during the taxable year 1922 were charged off within the meaning of section 214(a) (7) of the Revenue Act of 1921. It is apparent from the record that the accounts sought to be charged off had been included as income…
2Cited by4 opinions
- Brown v. United StatesCourt of Appeals for the Third Circuit · 1938
- American Cigarette & Cigar Co. v. BowersDistrict Court, S.D. New York · 1937
- Brown v. United StatesCourt of Appeals for the Third Circuit · 1938
- Pate v. CommissionerUnited States Board of Tax Appeals · 1928