AMERICAN SAV. BANK & TRUST CO. v. BURNET

No. 6220.

45 F.2d 548 (1930)

AMERICAN SAV. BANK & TRUST CO. v. BURNET, Commissioner of Internal Revenue.

Circuit Court of Appeals, Ninth Circuit.

December 6, 1930.


Attorney(s) appearing for the Case

James H. Kane, of Seattle, Wash., for petitioner.

G. A. Youngquist, Asst. Atty. Gen., and Sewall Key and Andrew D. Sharpe, Sp. Assts. to Atty. Gen. (C. M. Charest, Gen. Counsel, and Frank M. Thompson, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for respondent.

Before RUDKIN and WILBUR, Circuit Judges, and NORCROSS, District Judge.


WILBUR, Circuit Judge.

The petitioner, in its income tax return for the year 1920, claims a deduction of $30,000 on account of the depreciated value of a debt. The Commissioner denied this allowance on the ground that the debt of $70,000 was ascertained to be worthless to the extent of $30,000 in the previous taxable year, 1919. The Board of Tax Appeals found the facts in accordance with the stipulation of the parties, and, from the facts stipulated and from the oral...

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