Parker v. Commissioner
United States Tax Court
Under the facts it is held that petitioner sustained a loss in a transaction entered into for profit which is deductible under section 23 (e) (2) of the Internal Revenue Code. Robert Lyons Hague, 24 B.T.A. 288, distinguished.
1Opinion of the Court
OPINION.
HaRRON, Judge:
Petitioner claims a deduction under section 23 (e) (2) of the Internal Revenue Code for a loss sustained in a transaction entered into for profit. Respondent contends that there was a failure to enter into any transaction and cites Robert Lyons Hague, 24 B. T. A. 288, as authority for denying the claimed deduction.
In our opinion, the facts here are distinguishable from those in the Hague case, and it is not controlling.
In the Hague case, the taxpayer did no more than employ an attorney to advise him upon the matter of whether or not he should purchase certain property…
2Cited by19 opinions
- Frank v. CommissionerUnited States Tax Court · 1953
- Dwight A. Ward v. Commissioner of Internal Revenue, Hanna P. Ward v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- Seed v. CommissionerUnited States Tax Court · 1969
- Brown v. CommissionerUnited States Tax Court · 1963
- Gawler v. CommissionerUnited States Tax Court · 1973
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