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L. A. CLARKE & SON, INC. v. COMMISSIONER

Docket No. 28941.

17 T.C. 1120 (1952)

L. A. CLARKE & SON, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated January 8, 1952.

Attorney(s) appearing for the Case

Joseph K. Moyer, Esq., for the petitioner.

Stephen P. Cadden, Esq., for the respondent.

OPINION.

RAUM, Judge:

The Commissioner determined a $9,362.42 deficiency in income tax for the year 1945 as a result of disallowing a deduction in the amount of $18,607.29 which had been claimed by petitioner on a consolidated return as a bad debt from a subsidiary corporation. Petitioner now contends, in the alternative, that it is also entitled to the deduction as a "loss" with respect to its unrecouped investment in the stock of the subsidiary...

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