Appeal of J. K. BOWMAN, J. W. BOWMAN, and H. H. BOWMAN, Copartners under the name of Bowman & Co.

Appeal of J. K. BOWMAN, J. W. BOWMAN, and H. H. BOWMAN, Copartners under the name of Bowman & Co. Docket No. 39. Submitted September 26, 1924; decided November 14, 1924. Paul G. Smith, Esq., for the taxpayers. Robert A. Littleton, Esq. (Nelson T. Hartson, Solicitor of Internal .Revenue) for the Commissioner. Before SteeNHAgeN, Trammell, and Teussell. The only issue presented at the hearing related to a disallowance by the Commissioner in the income tax return of the partnership of certain claimed deductions on account of bad debts. The parties thereafter stipulated that of $21,613.17 bad debts deducted by the partnership and disallowed by the Commissioner, the sum of $16,935.27 represented debts ascertained to be worthless and charged off within the taxable year and the sum of $4,677.90 represented accounts not determined to be worthless and not charged off as such. The parties have further stipulated, with respect to the tax liability of each individual partner, that the correct deficiency in the case of J. W. Bowman is $1,479.93 on account of income tax for the year 1919; that the correct deficiency for the same year in the case of H. H. Bowman is $964.62, and of J. K. Bowman $834.93. [MAJORITY] DECISION. The Board determines that the deficiency, as determined by the Commissioner with respect to the income tax liability for the year 1919 of J. W. Bowman, H. H. Bowman, and J. K. Bowman, is allowed in part and disallowed in part, and that the deficiency as to J. W. Bowman is $1,479.93, as to H. H. Bowman is $964.62, and as to J. K. Bowman is $834.93.