Nixon v. Commissioner

The taxpayer appeals from a determination of deficiencies in income tax in the amounts of $122.76 and $2,618.78 for the calendar *525years 1919 and 1920, respectively. The deficiency for 1919 results from the disallowance by the Commissioner of a claimed bad debt in the amount of $6,137.50. The deficiency for 1920 is the result of the addition by the Commissioner of $16,700 to the reported profit on the sale of real estate.

Counsel stipulated that the facts in the case as determined by the Solicitor of Internal Revenue and set forth in Recommendation No. F 1515 may be found as facts by the Board,…