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HARMOUNT v. COMMISSIONER OF INTERNAL REVENUE

No. 5872.

58 F.2d 118 (1932)

HARMOUNT v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Sixth Circuit.

May 3, 1932.

Attorney(s) appearing for the Case

Chas. P. Taft, 2d., of Cincinnati, Ohio (Taft, Stettinius & Hollister, of Cincinnati, Ohio, on the brief), for petitioner.

J. M. Hudson, of Washington, D. C. (G. A. Youngquist, Asst. Atty. Gen., and Sewall Key, Wm. Earl Smith, C. M. Charest, and Robert L. Williams, all of Washington, D. C., on the brief), for respondent.

Before MOORMAN, HICKS, and SIMONS, Circuit Judges.

SIMONS, Circuit Judge.

The decision sought to be reviewed is that of the United States Board of Tax Appeals sustaining a deficiency assessment by the Commissioner of Internal Revenue against the petitioner herein for income tax for the year 1920. The determination of the tax resulted from the disallowance of a deduction claimed for a bad debt against the Michigan Central Railroad Company in the amount of $21,714.30.

The deduction was claimed upon the following...

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