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PORTUGUESE-AMERICAN TIN COMPANY v. COMMISSIONER

Docket No. 110785.

2 T.C.M. 270 (1943)

The Portuguese-American Tin Company v. Commissioner.

United States Tax Court.

Entered June 15, 1943.

Attorney(s) appearing for the Case

Scott C. Lambert, Esq., 225 Bush St., San Francisco, Calif., and Sigvald Nielson, Esq., 225 Bush St., San Francisco, Calif., for the petitioner. Harry R. Horrow, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

MELLOTT, Judge:

This proceeding involves a deficiency in income tax for the calendar year 1939 in the amount of $1,694.93. The sole issue is whether the Commissioner erred in disallowing a bad debt deduction in the amount of $14,217.49, claimed by petitioner in its income tax return, and in treating the amount as a capital loss, deductible, under the provisions of section...

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