Davis v. Commissioner
United States Board of Tax Appeals
The petitioner was the guarantor of certain notes given by the Multitone Manufacturing Co. This company went into the hands of a receiver in 1921. The petitioner then gave to the payee of the notes his own notes and received the notes upon which he was guarantor.
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The petitioner was the guarantor of certain notes given by the Multitone Manufacturing Co. This company went into the hands of a receiver in 1921. The petitioner then gave to the payee of the notes his own notes and received the notes upon which he was guarantor. He made a claim against the receiver of the corporation for the amount of the notes guaranteed by him and in 1921 received a final liquidating dividend from the Multitone Manufacturing Co.Held that since the petitioner made his income-tax return for 1921 on a cash receipts and disbursements basis, he is not entitled to deduct from…
1Opinion of the Court
*757OPINION.
Littleton :
Section 212 of the Revenue Act of 1921 provides:(a) That in tlie case of an individual the term “ net income ” means the gross income as defined in section 213, less the deductions allowed by section 214.(b) The net income shall be computed upon the basis of the taxpayer’s annual accounting period (fiscal year or calendar year, as the case may be) in accordance with the method of accounting regularly employed in keeping the books of such taxpayer; * * *
Section 214 (a) of the Revenue Act of 1921 permits the deduction from gross income of individuals of ally-(4) Losses…
2Cited by2 opinions
- Davis v. CommissionerUnited States Board of Tax Appeals · 1927
- Sass v. CommissionerUnited States Board of Tax Appeals · 1928