Sidney Ross Co. v. Commissioner
United States Board of Tax Appeals
The amount of certain advances made by petitioner in 1921 to its branch office in China, which it carried on its books as accounts receivable and charged off in 1923, held, upon the record, not to be shown to have represented a loss sustained in 1923.
1Opinion of the Court
*501OPINION.
Leech: The issue presented here is, Did petitioner sustain a deductible loss in 1923 under the provisions of section 234 (a) (4) of the Revenue Act of 1921 ?
The “ advances ” claimed as the basis for the loss were commingled with the general funds of the China Ross Company from which its general operating expenses were paid in an amount exceeding $25,000 during 1921. If a definite amount of the funds so advanced was used in the purchase of capital assets or for any other purpose, which, upon proper proof would furnish a basis for the loss, the record does not disclose such fact. There…
2Cited by3 opinions
- WF Young, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1941
- Dell v. CommissionerUnited States Tax Court · 1995
- Sidney Ross Co. v. CommissionerUnited States Board of Tax Appeals · 1932