Grenada Bank v. Commissioner
United States Board of Tax Appeals
1. Losses by embezzlement to the extent not compensated for by recoveries are deductible, not as bad debts determined to be worthless and charged off during the taxable year, but as losses sustained. 2. Amounts paid as interest on the obligations of the taxpayer may not be deducted as losses sustained. 3. The amounts recovered with respect to the embezzlements were generally recovered with reference to the total amount embezzled and without regard to any particular item or…
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1. Losses by embezzlement to the extent not compensated for by recoveries are deductible, not as bad debts determined to be worthless and charged off during the taxable year, but as losses sustained. 2. Amounts paid as interest on the obligations of the taxpayer may not be deducted as losses sustained. 3. The amounts recovered with respect to the embezzlements were generally recovered with reference to the total amount embezzled and without regard to any particular item or items embezzled. In computing the loss deduction for the taxable year the respondent allocated the recoveries to the…
1Opinion of the Court
GRENADA BANK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Grenada Bank v. Commissioner
Docket No. 54900.
United States Board of Tax Appeals
32 B.T.A. 1290; 1935 BTA LEXIS 824;
August 29, 1935, Promulgated
1. Losses by embezzlement to the extent not compensated for by recoveries are deductible, not as bad debts determined to be worthless and charged off during the taxable year, but as losses sustained.
2. Amounts paid as interest on the obligations of the taxpayer may not be deducted as losses sustained.
3. The amounts recovered with respect to the embezzlements were generally…
2Cases cited3 opinions
- Peterson Linotyping Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Gottlieb Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Grenada Bank v. CommissionerUnited States Board of Tax Appeals · 1935