Capital City State Bank v. Commissioner
This text of 13 B.T.A. 304 (Capital City State Bank v. Commissioner) 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.
Opinion
OPINION.
It appears from the evidence that at the date of the charge-off for which deduction is here claimed the petitioner held collateral taken as security for each of the notes alleged to have become worthless in the taxable year. The action of the Commissioner in disallowing the deductions claimed is approved (1) because, as to the Bristol note, under the Revenue Act of 1918 no partial charge-off of a debt alleged to be worthless is authorized, and (2) because, as to each of the notes in question, the petitioner held col[305]*305lateral of some value, and at that date it was impossible to determine that any loss had been sustained. Steele Cotton Mill Co., 1 B. T. A. 299; Murchison National Bank, 1 B. T. A. 617; Cherry Basset Co., 2 B. T. A. 426; Desolge Consolidated Lead Co., 4 B. T. A. 139; Blaine County National Bank, 2 B. T. A. 966; Joseph H. Reid Estate, 2 B. T. A. 1198; Minnehaha National Bank, 8 B. T. A. 401.
Decision will he entered for the respondent.
Free access — add to your briefcase to read the full text and ask questions with AI
Related
Cite This Page — Counsel Stack
13 B.T.A. 304, 1928 BTA LEXIS 3270, Counsel Stack Legal Research, https://law.counselstack.com/opinion/capital-city-state-bank-v-commissioner-bta-1928.