Morton v. Commissioner
United States Board of Tax Appeals
1. Petitioner was a member of a syndicate formed for the purpose of financing a corporation engaged in building and operating a cooperative apartment. The syndicate by its manager borrowed money and executed a note. The petitioner paid his pro rata share of the interest on the note to the corporation which paid the interest to the payee of the note.
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1. Petitioner was a member of a syndicate formed for the purpose of financing a corporation engaged in building and operating a cooperative apartment. The syndicate by its manager borrowed money and executed a note. The petitioner paid his pro rata share of the interest on the note to the corporation which paid the interest to the payee of the note. Held, such payment of interest is deductible from petitioner's gross income. 2. Petitioner held common stock in a corporation engaged in operating an investment trust. In 1931 the corporation held assets worth $42,000, and had liabilities of…
1Opinion of the Court
*1271OPINION.
Kern:
This proceeding involves that part of a deficiency of $2,159.05 determined by respondent in petitioner’s income tax liability for the year 1932 which arises by reason of (1) respondent’s disallowance of a deduction claimed by petitioner in the sum of $848.32, representing interest paid by him on an obligation of the Twelve-Sixty Astor Street Building Syndicate, (2) respondent’s disallowance of a deduction taken by petitioner in the sum of $3,625, representing an investment in common stock of the First Investors Co. of Illinois and claimed by him to have become worthless in that…
2Cases cited5 opinions
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
- Helvering v. New York Trust Co.Supreme Court of the United States · 1934
- McFeely v. CommissionerSupreme Court of the United States · 1935
- Slater v. George M. Clark & Co.Appellate Court of Illinois · 1897
3Cited by108 opinions
- Dustin v. CommissionerUnited States Tax Court · 1969
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- Steadman v. Comm'rUnited States Tax Court · 1968
- Charles W. Steadman and Dorothy F. Steadman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1970
- Denver & R. G. W. R. Co. v. CommissionerUnited States Tax Court · 1959
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