Pryibil v. Commissioner
United States Board of Tax Appeals
1. DEDUCTION - LOSS. - Held, petitioner was not entitled to a loss deduction where he failed to establish that stock did not become worthless prior to 1928, as determined by respondent. 2. Id. - BAD DEBT. - Held, petitioner was not entitled to a bad debt deduction where he failed to establish his ascertainment of the worthlessness of a debt apparently worthless prior to the taxable year.
1Opinion of the Court
OPINION.
Leech :
This proceeding seeks the redetermination of a deficiency of $11,321.18 for the calendar year 1928. The total deficiency is not in controversy. The only issue is whether respondent erred in disallowing a deduction of $91,027.97 claimed as a bad debt.
Petitioner is an individual having his office in New York City, and is engaged in the business of a stock broker. Prior to 1929, he was engaged chiefly in the real estate business.
In 1925 petitioner went to Florida and organized- a corporation under the laws of that state, known as Pryibil & Co., to engage in the real estate…
2Cases cited4 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Van Dyke v. CommissionerUnited States Board of Tax Appeals · 1931
- D. P. Harris Hardware & Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Steinback v. CommissionerUnited States Board of Tax Appeals · 1934
3Cited by5 opinions
- Cammack v. United StatesCourt of Appeals for the Eighth Circuit · 1940
- Kimmelman v. CommissionerUnited States Tax Court · 1943
- Pryibil v. CommissionerUnited States Board of Tax Appeals · 1934
- Ridgway v. CommissionerUnited States Board of Tax Appeals · 1936
- T. T. Word Supply Co. v. CommissionerUnited States Board of Tax Appeals · 1940