Ames v. Commissioner
United States Board of Tax Appeals
1. Where there is a bona fide sale of a chose in action (in this case a debt due to the petitioner for money loaned) for a consideration, and the debt is not in fact worthless, the taxpayer sustained a deductible loss in the amount of the difference between the amount of the debt assigned and the amount of the consideration received. 2. In a prior year the taxpayer exchanged a note receivable of one corporation for the cancellation of his indebtedness to another corporation…
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1. Where there is a bona fide sale of a chose in action (in this case a debt due to the petitioner for money loaned) for a consideration, and the debt is not in fact worthless, the taxpayer sustained a deductible loss in the amount of the difference between the amount of the debt assigned and the amount of the consideration received. 2. In a prior year the taxpayer exchanged a note receivable of one corporation for the cancellation of his indebtedness to another corporation and an account receivable payable in monthly installments, with interest upon the unpaid balance. Of each monthly…
1Opinion of the Court
WARD AMES, JR., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Ames v. Commissioner
Docket No. 49817.
United States Board of Tax Appeals
27 B.T.A. 624; 1933 BTA LEXIS 1338;
January 31, 1933, Promulgated
1. Where there is a bona fide sale of a chose in action (in this case a debt due to the petitioner for money loaned) for a consideration, and the debt is not in fact worthless, the taxpayer sustained a deductible loss in the amount of the difference between the amount of the debt assigned and the amount of the consideration received.
2. In a prior year the taxpayer exchanged a note…
2Cases cited1 opinion
- Ames v. CommissionerUnited States Board of Tax Appeals · 1933