
    American Savings Bank & Trust Co., Petitioner, v. Commissioner of Internal Revenue, Respondent.
    Docket No. 18478.
    Promulgated November 30, 1929.
    
      J. H. Kane, Esq., and Carl G. Prestrud, O. P. A., for the petitioner.
    
      A. H. Fast, Esq., for the respondent.
   OPINION.

Geeen :

The petitioner contends that the debt became worthless in 1920. Its principal witness, now chairman of the board of directors of the successor bank and president of the petitioner in 1920, testified that the debt became worthless in 1919. We know of no case in which a taxpayer has been permitted to take a deduction for a bad debt in a year subsequent to the ascertainment of worthlessness of such debt.

Judgment will be entered for the respondent.  