
    Guthrie Shaw, Executor, Estate of James G. Shaw, Jr., Petitioner, v. Commissioner of Internal Revenue, Respondent.
    Docket No. 9644.
    Promulgated December 1, 1927.
    
      G. N. Nelson, Esq., for the petitioner.
    
      L. 0. Mitchell, Esq., for the respondent.
   OPINION.

Trussell:

Upon the record we are of the opinion that decedent had ascertained during 1920 that the debt in question became worthless, and, inasmuch as he kept no books, there could be no physical charge-off, but decedent’s statement during 1920 that the amount could be forgotten was in effect a charge-off of the bad debt.

Judgment will be entered upon 15 days’ notice, pursuant to Bule 50.

Considered by Smith, Love, and Littleton.  