Martin v. Commissioner
United States Tax Court
Deductions -- Bad Debts -- 'Certificate of Indebtedness Issued by a Corporation in Registered Form" -- Section 23 (k) (3). -- Installment investment certificate in a California building and loan association held to be a certificate of indebtedness issued by a corporation in registered form within the meaning of section 23 (k) of the Internal Revenue Code.
1Opinion of the Court
OPINION.
Mukdock, Judge:
Both parties to this proceeding recognize that these petitioners sustained losses in 1941. The amount of those losses is not in dispute. The association owed the petitioners certain amounts shown as final credits upon their investment certificates at the beginning of 1936. The petitioners have recovered 75 per cent of those debts from their debtor, 70 per cent through shares of the debtor received in 1936, and 5 per cent through additional shares or additional credits to shares in 1941. The remaining 25 per cent of the amounts due upon those-investment certificates has…
2Cases cited2 opinions
- Caulkins v. CommissionerUnited States Tax Court · 1943
- Puelicher v. CommissionerUnited States Tax Court · 1946
3Cited by1 opinion
- Martin v. CommissionerUnited States Tax Court · 1946