Legal Opinion

Ames v. Commissioner

United States Board of Tax Appeals

Decided January 31, 1933No. Docket No. 49817Published

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

  1. Ames v. CommissionerUnited States Board of Tax Appeals · 1933

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