Gertz v. Commissioner
United States Tax Court
Petitioner claimed a bad debt deduction under sec. 166 for wages never paid. Held, respondent did not err is disallowing the bad debt deduction since petitioner had never reported the amount claimed in income, as required by sec. 1.166-1(e), Income Tax Regs.Held, further, petitioner is not entitled to claim a tax credit for wages his employer was never liable to withhold.
1Opinion of the Court
Irwin, Judge:
Respondent determined a deficiency in petitioner’s income tax for the calendar year 1969 in the amount of $1,209.87. Various concessions having been made, the only issue remaining for our determination is whether respondent erred in disallowing a claimed bad debt deduction for wages which were never paid.
FINDINGS OF FACT
Some of the facts have been stipulated and these facts are found accordingly.
Petitioners are husband and wife and resided in Laguna Hills, Calif., at the time of the filing of their petition in this case. For the calendar year 1969 they filed their joint Federal…
2Cases cited5 opinions
- Bush Terminal Bldgs. Co. v. CommissionerUnited States Tax Court · 1946
- United States v. FogartyCourt of Appeals for the Eighth Circuit · 1947
- Collin v. CommissionerUnited States Board of Tax Appeals · 1925
- Simons v. CommissionerUnited States Board of Tax Appeals · 1925
- In Re Freedomland, Inc.District Court, S.D. New York · 1972
3Cited by28 opinions
- FARNSWORTH v. COMMISSIONERUnited States Tax Court · 2002
- Cardosi v. CommissionerUnited States Tax Court · 1995
- Powell v. Comm'rUnited States Tax Court · 2014
- Crosson v. Comm'rUnited States Tax Court · 2003
- Hutton v. CommissionerUnited States Tax Court · 1976
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