First Nat'l Bank v. Commissioner
United States Board of Tax Appeals
1. Evidence of a national bank that an asset account representing Russian bonds was in 1921 reduced by amounts "charged off" by order of a national bank examiner held insufficient to established a deductible loss or bad debt. 2. No deduction in respect of reduced value of Russian Imperial bonds may be taken unless the loss provision of the statute is fulfilled. First National Bank of St. Paul,10 B.T.A. 32, followed.
1Opinion of the Court
*1388OPINION.
Sternhagen:
The facts before us indicate nothing as to actual worthlessness of the bonds or that a loss was in fact realized. The single reason for “ charging them off ” was an order of a national bank examiner. This does not prove either a loss sustained, under section 234 (a) (4) or a debt ascertained to be worthless under section 234 (a) (5), Revenue Act of 1921, Murchison National Bank, 1 B. T. A. 617; Farmers & Traders Bank, 4 B. T. A. 753; Continental Trust Co., 7 B. T. A. 539, 554. Nor are the facts sufficient to show the extent to which the debts, if they were to be treated as…
2Cited by1 opinion
- First Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1928