Appeals Stockbridge

United States Board of Tax Appeals

Decided July 11, 1925

United States Board of Tax Appeals · decided 1925-07-11

Cited by 4 later decisions (1 by the Supreme Court) — most recently February 1930

Relies on Austin v. Commissioner · Consolidated Asphalt Co. v. Commissioner · Uvalde Co. v. Commissioner

Good law ✅— No negative treatment on recordhow we know

Decided 1925-07-11

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¶1 *328OPINION.

Ivins:

¶2We are satisfied by evidence submitted by the taxpayers-,, and uncontroverted, that depreciation should be allowed the partnership for the fiscal year ended June 30, 1919, in the amount of $29,698.73.

¶3The item of $22,000 was not a proper deduction for the fiscal year in question. At the end of that year it represented not an accrued liability but a reserve.

¶4During the fiscal year in question claims existed only in contemplation, not in fact. They did not arise and so accrue until after the-close of the fiscal year. Appeal of Consolidated Asphalt Co., 1 B. T. A. 79; Appeal of Henry Reubel, 1 B. T. A. 676; Appeal of Uvalde Co., 1 B. T. A. 932; Appeal of William J. Ostheimer, 1 B. T. A. 18.