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MOMSEN-DUNNEGAN-RYAN CO. v. HELVERING

No. 5680.

68 F.2d 754 (1933)

MOMSEN-DUNNEGAN-RYAN CO. v. HELVERING, Com'r of Internal Revenue.

Court of Appeals of the District of Columbia.

Rehearing Denied January 22, 1934.

Attorney(s) appearing for the Case

J. S. Y. Ivins and Richard B. Barker, both of Washington, D. C., for appellant.

Sewall Key, G. A. Youngquist, C. M. Charest, John D. Kiley, and S. Dee Hanson, all of Washington, D. C., for appellee.

Before MARTIN, Chief Justice, and ROBB, VAN ORSDEL, HITZ, and GRONER, Associate Justices.

HITZ, Associate Justice.

The applicable statutes are the Revenue Acts of 1921 and 1924 (42 Stat. 227, 255; 43 Stat. 253, 284, 26 USCA § 986 (a) (5). Section 234 (a) (5) of each of those acts allows a corporation to deduct from its gross income "debts ascertained to be worthless and charged off within the taxable year (or in the discretion of the commissioner, a reasonable addition to a reserve for bad debts)."

This alternative method of return, by reserving...

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