PUTNAM NAT. BANK v. COMMISSIONER OF INTERNAL REVENUE

No. 6173.

50 F.2d 158 (1931)

PUTNAM NAT. BANK v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

May 27, 1931.


Attorney(s) appearing for the Case

J. V. Walton and Thos. B. Dowda, both of Palatka, Fla., for petitioner.

G. A. Youngquist, Asst. Atty. Gen., Sewall Key, Sp. Asst. to Atty. Gen., C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and James K. Polk, Jr., Sp. Atty. Bureau of Internal Revenue, both of Washington, D. C., J. Louis Monarch and Norman D. Keller, Sp. Assts. to Atty. Gen., for respondent.

Before BRYAN, SIBLEY, and HUTCHESON, Circuit Judges.


HUTCHESON, Circuit Judge.

Petitioner, having in 1921 made a partial charge off and had allowed as a bad debt a deduction of $18,000 on account of bonds held by it, was required by the Commissioner when that amount was collected on the bonds in 1925, to return it as taxable income for that year. On appeal to the Board of Tax Appeals, the action of the Commissioner was sustained, and the case comes here for review of the Board's decision.

The facts, as stipulated...

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