Kay Mfg. Co. v. Commissioner
United States Board of Tax Appeals
1. The petitioner, having elected for 1921 to take deductions for specific bad debts, may not change to a reserve basis for that year and subsequent years. 2. The respondent mailed a deficiency notice to a former address of petitioner, which notice was actually received by petitioner at its new address, and a petition was filed with the Board within the time required by law.
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1. The petitioner, having elected for 1921 to take deductions for specific bad debts, may not change to a reserve basis for that year and subsequent years. 2. The respondent mailed a deficiency notice to a former address of petitioner, which notice was actually received by petitioner at its new address, and a petition was filed with the Board within the time required by law. Held, any defects in the address were waived by the filing of the petition. 3. Certain cash discounts accrued by petitioner at the close of 1925, and freight allowances for the years 1923 to 1925, inclusive, disallowed…
1Opinion of the Court
*759OPINION.
Makquette :
The first assignment of error in Docket No. 26865 and the first five assignments of error in Docket No. 33608 may be considered and disposed of together. The following tabulation shows, for each of the years on appeal, the total of debts charged against the reserve for bad debts, the addition to the reserve for bad debts, the deduction for bad debts taken in return, and the deduction for bad debts allowed by the respondent:
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The addition to the reserve for bad debts for 1922 of $11,356.97 was not recorded on the books until June 14,1923, but was claimed as a…
2Cited by17 opinions
- Lifter v. CommissionerUnited States Tax Court · 1973
- Clodfelter v. CommissionerUnited States Tax Court · 1971
- Manistique Lumber & Supply Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Scruggs v. CommissionerUnited States Board of Tax Appeals · 1934
- Century Die Casting Co. v. CommissionerUnited States Tax Court · 1943
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