United States Board of Tax Appeals May 20, 1925, Docket No. 750 (Appeal of Portland Railway, Light & Power Co.)

*1153OPINION.

James: Upon the first point the determination, under prior decisions of the Board, must be in favor of the Commissioner. The taxpayer in this appeal alleges that the railway company was insolvent ; that it was forced to advance the sums of money in question to pay the interest and sinking-fund requirements of the bonds which it had guaranteed, and is, therefore, entitled to deduct