Opinion

Citizens State Bank v. Commissioner

  • 46 B.T.A. 964
  • 1942 BTA LEXIS 796
Court
United States Board of Tax Appeals
Filed
Apr 14, 1942
Status
Published
Author
Disney
On the bench
Sternhagen, Murdoch, Disney, Hill
Cited by
7 cases

The opinion

Disney,

dissenting: The deduction for bad debts can be said to have no tax benefit only where there is no gross income against which to apply it. If there is gross income it seems mathematically inescapable that each class of deduction contributes proportionately to *972 any net loss and that one category of deductions, for instance bad debts, should not be arbitrarily singled out as causing the net loss, contrary to fact and logic. A rule of allocation would, moreover, be more easily administrable, as is evidenced by the questions raised by the opposite rule applied by the majority opinion. I dissent.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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