Appeal of Pomeroy

Board of Tax Appeals

Appeal of Pomeroy

2 B.T.A. 228

CourtUnited States Board of Tax Appeals

DecidedJune 30, 1925

DocketDocket No. 3161

StatusPublished

Cited by1 cases

This text of 2 B.T.A. 228 (Appeal of Pomeroy) 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.

Bluebook

Appeal of Pomeroy, 2 B.T.A. 228 (bta 1925).

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Opinion

The taxpayer appeals from the determination of a deficiency in income taxes of less than $10,000 for the calendar year 1918, resulting from the disallowance of a deduction for an alleged worthless debt of $16,700 by the partnership of which he was a member.

FINDINGS OF FACT.

In 1918 the partnership of Dives, Pomeroy & Stewart, of which the taxpayer was a member, was the owner of certain bonds of the DuPont Land Co., which, according to its books, represented a cost to the partnership of $16,700. At the end of the year 1918, believing these bonds to be worthless, the partnership charged them off its books and deducted that amount on its partnership income-tax return. The facts upon which the partnership acted in writing off the amount were that, in response to inquiries, one broker had said that he had heard nothing about the bonds for some time, and another had said that he thought the bonds had no value; also, that there were rumors.

DECISION.

The determination of the Commissioner is approved.

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The taxpayer appeals from the determination of a deficiency in income taxes of less than $10,000 for the calendar year 1918, resulting from the disallowance of a deduction for an alleged worthless debt of $16,700 by the partnership of which he was a member.

FINDINGS OF FACT.

In 1918 the partnership of Dives, Pomeroy & Stewart, of which the taxpayer was a member, was the owner of certain bonds of the DuPont Land Co., which, according to its books, represented a cost to the partnership of $16,700. At the end of the year 1918, believing these bonds to be worthless, the partnership charged them off its books and deducted that amount on its partnership income-tax return. The facts upon which the partnership acted in writing off the amount were that, in response to inquiries, one broker had said that he had heard nothing about the bonds for some time, and another had said that he thought the bonds had no value; also, that there were rumors.

DECISION.

The determination of the Commissioner is approved.

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Bluebook (online)

2 B.T.A. 228, Counsel Stack Legal Research, https://law.counselstack.com/opinion/appeal-of-pomeroy-bta-1925.

Opinion

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