Legal Opinion

Pryibil v. Commissioner

United States Board of Tax Appeals

Decided September 14, 1934No. Docket No. 58952PublishedCited by 5 opinions

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

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Van Dyke v. CommissionerUnited States Board of Tax Appeals · 1931
  3. D. P. Harris Hardware & Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1931
  4. Steinback v. CommissionerUnited States Board of Tax Appeals · 1934

3Cited by5 opinions

  1. Cammack v. United StatesCourt of Appeals for the Eighth Circuit · 1940
  2. Kimmelman v. CommissionerUnited States Tax Court · 1943
  3. Pryibil v. CommissionerUnited States Board of Tax Appeals · 1934
  4. Ridgway v. CommissionerUnited States Board of Tax Appeals · 1936
  5. T. T. Word Supply Co. v. CommissionerUnited States Board of Tax Appeals · 1940

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