Legal Opinion

Ewald & Co. v. Commissioner

United States Board of Tax Appeals

Decided February 13, 1930No. Docket No. 34226Published

1. The petitioner took deductions for bad debts in its return for 1921 by the charge-off method, and thereafter, in 1922, changed to the reserve method, claiming deductions of additions to a reserve for bad debts, without first having obtained permission of the Commissioner to change to the latter method. Held that the deductions for additions to the reserve for bad debts may not be allowed.

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1. The petitioner took deductions for bad debts in its return for 1921 by the charge-off method, and thereafter, in 1922, changed to the reserve method, claiming deductions of additions to a reserve for bad debts, without first having obtained permission of the Commissioner to change to the latter method. Held that the deductions for additions to the reserve for bad debts may not be allowed. Kay Manufacturing Co.,18 B.T.A. 753. 2. Held, further, that the petitioner in computing net income is entitled to deduct the total amount of debts ascertained to be worthless and charged off within each…

1Opinion of the Court

EWALD & CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Ewald & Co. v. Commissioner

Docket No. 34226.

United States Board of Tax Appeals

18 B.T.A. 1130; 1930 BTA LEXIS 2520;

February 13, 1930, Promulgated

1. The petitioner took deductions for bad debts in its return for 1921 by the charge-off method, and thereafter, in 1922, changed to the reserve method, claiming deductions of additions to a reserve for bad debts, without first having obtained permission of the Commissioner to change to the latter method. Held that the deductions for additions to the reserve for bad debts may not…

2Cases cited2 opinions

  1. Kay Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1930
  2. Ewald & Co. v. CommissionerUnited States Board of Tax Appeals · 1930

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