# Citizens State Bank v. Commissioner > United States Board of Tax Appeals · April 14, 1942 · 46 B.T.A. 964 URL: https://www.frixlaw.com/law-library/cases/4499054 ## Case - **Full name:** CITIZENS STATE BANK, v. COMMISSIONER OF INTERNAL REVENUE - **Court:** United States Board of Tax Appeals - **Decided:** April 14, 1942 - **Citations:** 46 B.T.A. 964; 1942 BTA LEXIS 796 - **Precedential status:** Published - **Opinion:** Dissent by Disney - **Judges:** Sternhagen, Murdoch, Disney, Hill - **Cited by:** 7 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/4499054 ## Opinion text 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. --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4499054. Public record. Not legal advice.