# Towers v. Commissioner > United States Tax Court · May 18, 1955 · 24 T.C. 199 URL: https://www.frixlaw.com/law-library/cases/4477064 ## Case - **Full name:** Samuel Towers, v. Commissioner of Internal Revenue - **Court:** United States Tax Court - **Decided:** May 18, 1955 - **Citations:** 24 T.C. 199; 1955 U.S. Tax Ct. LEXIS 187 - **Precedential status:** Published - **Opinion:** Dissent by Murdock - **Judges:** Fisher,Arundell - **Cited by:** 73 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4477064 ## Opinion text Murdock, J., dissenting: I disagree with the result and reasoning on a number of issues including those mentioned below. The evidence seems sufficient to justify allowance of the bad debts as business bad debts. It is held that the 1945 distributions by Rumsey Mfg. of the “Donated Surplus Account” represented repayment of loans and, since that decided the only issue stated, it is error to go further and decide a point not raised in connection with those repayments. The retirement of the preferred stock of Rumsey Mfg. in 1945 was not shown to be within section 115 (g). I think “the remainder of the lump-sum payment” in the “Barrand and Williams purchase” should be allocated. Cohan v. Commissioner, 39 F. 2d 540 . --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4477064. Public record. Not legal advice.