Tiller-Glenn Co. v. Commissioner

Board of Tax Appeals

Tiller-Glenn Co. v. Commissioner

4 B.T.A. 1051, 1926 BTA LEXIS 2105

CourtUnited States Board of Tax Appeals

DecidedSeptember 25, 1926

DocketDocket No. 6973.

StatusPublished

This text of 4 B.T.A. 1051 (Tiller-Glenn Co. 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.

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Tiller-Glenn Co. v. Commissioner, 4 B.T.A. 1051, 1926 BTA LEXIS 2105 (bta 1926).

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Opinion

[1052]*1052OPINION.

Smith:

In this proceeding the petitioner claims the right to deduct from gross income $667.25 for bad debts which it claims were worthless on December 31, 1919. They have never been charged off the petitioner’s books of account. The taxing statute permits the petitioner to deduct from gross income “ debts ascertained to be worthless and charged off within the taxable year.” Section 234 (a) (5). The evidence shows that the petitioner made no ascertainment of the worthlessness of the eleven accounts receivable, totaling $667.25, during the year 1919, and that it did not charge them off its books of account during that year.

Judgment for the Commissioner.

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[1052]*1052OPINION.

Smith:

In this proceeding the petitioner claims the right to deduct from gross income $667.25 for bad debts which it claims were worthless on December 31, 1919. They have never been charged off the petitioner’s books of account. The taxing statute permits the petitioner to deduct from gross income “ debts ascertained to be worthless and charged off within the taxable year.” Section 234 (a) (5). The evidence shows that the petitioner made no ascertainment of the worthlessness of the eleven accounts receivable, totaling $667.25, during the year 1919, and that it did not charge them off its books of account during that year.

Judgment for the Commissioner.

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4 B.T.A. 1051, 1926 BTA LEXIS 2105, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tiller-glenn-co-v-commissioner-bta-1926.