Legal Opinion

Lowell v. Commissioner

United States Board of Tax Appeals

Decided July 27, 1934No. Docket Nos. 68048, 68049Published

1. A specialist in stocks listed on the New York Stock Exchange, whose operations consist of matching buy and sell orders given to him by other brokers and of buying and selling his specialties on margin as a speculation, is not a dealer in such stocks and may not inventory them under article 105 of Regulations 74. Other securities acquired for investment and used as collateral for a margin account were not acquired for resale and as to such securities petitioners were not…

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1. A specialist in stocks listed on the New York Stock Exchange, whose operations consist of matching buy and sell orders given to him by other brokers and of buying and selling his specialties on margin as a speculation, is not a dealer in such stocks and may not inventory them under article 105 of Regulations 74. Other securities acquired for investment and used as collateral for a margin account were not acquired for resale and as to such securities petitioners were not dealers. 2. Assessments levied by the exchange on members for operating expenses are deductible as ordinary and necessary…

1Opinion of the Court

JAMES B. LOWELL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

JAMES RUSSELL LOWELL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Lowell v. Commissioner

Docket Nos. 68048, 68049.

United States Board of Tax Appeals

30 B.T.A. 1297; 1934 BTA LEXIS 1192;

July 27, 1934, Promulgated

1. A specialist in stocks listed on the New York Stock Exchange, whose operations consist of matching buy and sell orders given to him by other brokers and of buying and selling his specialties on margin as a speculation, is not a dealer in such stocks and may not inventory them under article 105…

2Cases cited1 opinion

  1. Lowell v. CommissionerUnited States Board of Tax Appeals · 1934

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