Taylor v. Commissioner of Internal Revenue

Sixth Circuit

Taylor v. Commissioner of Internal Revenue

95 F.2d 1018, 21 A.F.T.R. (P-H) 84, 1938 U.S. App. LEXIS 4334

Court of Appeals for the Sixth Circuit·Decided March 17, 1938·No. No. 7478·Published·Cited by 1 cases

Opinion

PER CURIAM.

It appearing to the court that, treating petitioner’s claims as claims for deductions from gross income because of “losses,” the petitioner has failed to carry the burden of proof that he sustained the losses or any portion thereof during the taxable years involved; and further, that treating the claims for deductions as “bad debts,” the petitioner has likewise failed to sustain the burden of proof that such claims or any portion thereof were ascertained to be worthless and were charged off within the taxable years involved, it is therefore ordered and adjudged that the decision of the Board of Tax Appeals be, and the same is in all things, affirmed.

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PER CURIAM.

It appearing to the court that, treating petitioner’s claims as claims for deductions from gross income because of “losses,” the petitioner has failed to carry the burden of proof that he sustained the losses or any portion thereof during the taxable years involved; and further, that treating the claims for deductions as “bad debts,” the petitioner has likewise failed to sustain the burden of proof that such claims or any portion thereof were ascertained to be worthless and were charged off within the taxable years involved, it is therefore ordered and adjudged that the decision of the Board of Tax Appeals be, and the same is in all things, affirmed.

Taylor v. Commissioner of Internal Revenue, 95 F.2d 1018, 21 A.F.T.R. (P-H) 84, 1938 U.S. App. LEXIS 4334 (6th Cir. 1938).

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Opinion

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