U.S. Court of Appeals for the Sixth Circuit, 1938

Taylor v. Commissioner of Internal Revenue

Taylor v. Commissioner of Internal Revenue
U.S. Court of Appeals for the Sixth Circuit · Decided March 17, 1938
95 F.2d 1018; 21 A.F.T.R. (P-H) 84; 1938 U.S. App. LEXIS 4334 (Federal Reporter, Second Series)

Counsel

Thos. O. Marlar, of Toledo, Ohj.o, for petitioner., James W. Morris, Sewall Key, and Herman Oliphant, all of Washington, D. C., for respondent.

Taylor v. Commissioner of Internal Revenue

Cases that cite this one

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Opinion of the Court

PER CURIAM.

It appearing to the court that, treating petitioner’s claims as claims for deductions from gross income because of “losses,” the petitioner has failed to carry the burden of proof that he sustained the losses or any portion thereof during the taxable years involved; and further, that treating the claims for deductions as “bad debts,” the petitioner has likewise failed to sustain the burden of proof that such claims or any portion thereof were ascertained to be worthless and were charged off within the taxable years involved, it is therefore ordered and adjudged that the decision of the Board of Tax Appeals be, and the same is in all things, affirmed.

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