Coombs v. Commissioner
United States Board of Tax Appeals
Petitions filed to contest the disallowance of a deduction taken by an individual on the cash basis for a net loss in 1926 and 1927 because in 1926 a suit had been instituted against him to recover an unpaid syndicate subscription made in 1920, in which suit he denied liability and which was pending in 1926 and 1927, held to be without merit, frivolous, and filed merely for delay.
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Petitions filed to contest the disallowance of a deduction taken by an individual on the cash basis for a net loss in 1926 and 1927 because in 1926 a suit had been instituted against him to recover an unpaid syndicate subscription made in 1920, in which suit he denied liability and which was pending in 1926 and 1927, held to be without merit, frivolous, and filed merely for delay. Damages awarded under section 911, Revenue Act of 1924, as amended by section 1000, Revenue Act 1926.
1Opinion of the Court
OPINION.
Sternhagen:
Deficiencies in the petitioner’s individual income taxes for 1926 of $19,912.53, and 1927 of $13,371.48, are assailed by the petitioner in these two proceedings. The petitioner made his returns on the basis of cash receipts and disbursements. In 1926 he deducted as a loss an amount of $157,024.01, which was the unpaid balance of a syndicate subscription which he had made several years earlier and for the recovery of which suit was instituted against him in 1926, which he defended on the ground of no liability and which remained pending and undecided throughout the year…
2Cited by7 opinions
- Wilkinson v. CommissionerUnited States Tax Court · 1979
- Hatfield v. CommissionerUnited States Tax Court · 1977
- Coombs v. CommissionerUnited States Board of Tax Appeals · 1933
- Hatfield v. CommissionerUnited States Tax Court · 1977
- Parmenter v. CommissionerUnited States Tax Court · 1981
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