General Tool & Engineering Co. v. Commissioner

Sixth Circuit Court of Appeals

Decided May 15, 1941.

Sixth Circuit Court of Appeals · decided 1941-05-15

Cited by 2 later decisions — most recently April 1953

2 federal appellate ·

2 counsel of record

Relies on Helvering v. Kehoe

Good law ✅— No negative treatment on recordhow we know

Decided 1941-05-15

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¶1Raymond A. Fox, of Detroit, Mich., for petitioner.

¶2Samuel O. Clark, Jr., J. P. Wenchel, Sewall Key, John W. Smith, and Michael H. Cardozo, IV, all of Washington, D. C., for respondent.

¶3Before SIMONS, ALLEN, and MARTIN, Circuit Judges.

¶4 *12ALLEN, Circuit Judge.

¶5This case came on to be heard on the record and briefs and oral argument of counsel; and it appearing that there is substantial evidence to support the finding of the Board of Tax Appeals that the amount of $4,337.79 deducted as a bad debt in the fiscal year ending February 28, 1936, represented an account which was known to petitioner’s officers to be worthless prior to the taxable year, and that such finding must be accepted by us (Helvering, Com’r, v. Kehoe, 309 U.S. 277, 279, 60 S.Ct. 549, 84 L.Ed. 751);

¶6The order of the Board of Tax Appeals is hereby affirmed.