Simons v. Commissioner
United States Board of Tax Appeals
1. Worthless debts arising from unpaid rents and similar items of taxable income are not properly deductible as bad debts unless the income such items represent has been treated as income and included in the return of income for the year in which the deduction as a bad debt is sought to be made or in a previous year. 2. Under the circumstances of this case the losses arising by theft of articles during the absence of taxpayer in Europe were sustained in the taxable year…
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1. Worthless debts arising from unpaid rents and similar items of taxable income are not properly deductible as bad debts unless the income such items represent has been treated as income and included in the return of income for the year in which the deduction as a bad debt is sought to be made or in a previous year. 2. Under the circumstances of this case the losses arising by theft of articles during the absence of taxpayer in Europe were sustained in the taxable year 1921. 3. The evidence does not establish the fact of a loss arising from theft of articles in 1922, after the return of the…
1Opinion of the Court
*353OPINION.
Korner:
The taxpayer contends that he is entitled to take as deductions from gross income on his personal return for the year 1922 certain items as follows: (a) A bad debt arising from loss of rents sustained by reason of his subletting his residence occasioned by his being required to make his residence in another city; (5) a bad debt arising from failure of his subtenants to pay gas, electric, and telephone bills during the period of their occupancy of the taxpayer’s residence as subtenants, which bills taxpayer was obliged to pay; (e) losses arising from theft during taxpayer’s…
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- Robert F. Goeller and Jeanette M. Goeller v. United StatesUnited States Court of Federal Claims · 2013
- Gertz v. CommissionerUnited States Tax Court · 1975
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