26 C.F.R. § 1.66-5
Effective date
Sections 1.66-1 through 1.66-4 are applicable on July 10, 2003. In addition, § 1.66-4 applies to any request for relief filed prior to July 10, 2003, for which the Internal Revenue Service has not issued a preliminary determination as of July 10, 2003.
Notes of Decisions
Cited in 2
cases, 1974–1974 · leading case: Young v. Comm'r, 33 T.C.M. 397 (Tax Ct. 1974).
Young v. Comm'r, 33 T.C.M. 397 (Tax Ct. 1974). “, provides that for tax purposes the character of a bad debt is determined by the relationship which the debt bears to the taxpayer's trade or business.”
Saia v. Comm'r, 33 T.C.M. 1391 (Tax Ct. 1974). “To apply this standard we must determine the taxpayer's overriding reason incurring the obligation and, in so doing "compare the risk against the potential reward and give proper emphasis to the objective rather than to the subjective.”
Annotations are extracted automatically from the opinions in the
Syfert caselaw corpus and ranked by authority, recency, and
treatment. Dots show Syfertize treatment of the citing case itself.