Appeal of Equinox Co.

Board of Tax Appeals

Appeal of Equinox Co.

2 B.T.A. 466

CourtUnited States Board of Tax Appeals

DecidedSeptember 7, 1925

DocketDocket No. 3021

StatusPublished

Cited by1 cases

This text of 2 B.T.A. 466 (Appeal of Equinox Co.) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Appeal of Equinox Co., 2 B.T.A. 466 (bta 1925).

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Opinion

[468]*468OPINION.

Morris:

The book value of the assets of the Equinox Spring Co. as of October 81, 1919, was $5,138.22, represented by cash, accounts receivable, inventories, machinery, and fixtures. The.principal liability was the debt of $15,100 to the taxpayer. There is no evidence in the record that these assets were not worth their book value or that the taxpayer would not be able to recover at least a part of the debt. During the 10 months immediately preceding the close of its fiscal year 1919 it recovered from the Equinox Spring Co. $5,244.49. We are therefore of the opinion that the debt was not ascertained to be worthless nor was it charged off in the fiscal year 1919. The lack of evidence as to the value of the assets of the debtor company during the taxpayer’s succeeding fiscal year forces us to conclude that the debt, although charged off, is not deductible for that year.

Aeundell net participating.

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[468]*468OPINION.

Morris:

The book value of the assets of the Equinox Spring Co. as of October 81, 1919, was $5,138.22, represented by cash, accounts receivable, inventories, machinery, and fixtures. The.principal liability was the debt of $15,100 to the taxpayer. There is no evidence in the record that these assets were not worth their book value or that the taxpayer would not be able to recover at least a part of the debt. During the 10 months immediately preceding the close of its fiscal year 1919 it recovered from the Equinox Spring Co. $5,244.49. We are therefore of the opinion that the debt was not ascertained to be worthless nor was it charged off in the fiscal year 1919. The lack of evidence as to the value of the assets of the debtor company during the taxpayer’s succeeding fiscal year forces us to conclude that the debt, although charged off, is not deductible for that year.

Aeundell net participating.

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2 B.T.A. 466, Counsel Stack Legal Research, https://law.counselstack.com/opinion/appeal-of-equinox-co-bta-1925.

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