Price v. Commissioner

PARKER, Circuit Judge.

This is a petition to review a decision of the Board of Tax Appeals, approving a deficiency assessment for the year 1932. The question involved relates to the deductibility of a loss which taxpayer claims to have sustained in that year on a contract of guaranty previously executed. The Board denied the deduction on the ground that taxpayer, who made his return on the cash receipts and disbursements basis, gave a note covering the loss and that this note was not paid until the year following.

The taxpayer, Julian Price, is president of the Jefferson Standard Life Insurance…