Martin v. Commissioner
United States Tax Court
Petitioner is an entertainer and has been so engaged in business since 1932. In 1942 he was the subject of certain unfavorable publicity while serving with the Armed Forces. After being honorably discharged from the service in 1945, petitioner returned to Hollywood to resume his movie career. As a consequence of the earlier unfavorable publicity, petitioner was unable to obtain employment in the motion picture industry or in most of the entertainment media.
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Petitioner is an entertainer and has been so engaged in business since 1932. In 1942 he was the subject of certain unfavorable publicity while serving with the Armed Forces. After being honorably discharged from the service in 1945, petitioner returned to Hollywood to resume his movie career. As a consequence of the earlier unfavorable publicity, petitioner was unable to obtain employment in the motion picture industry or in most of the entertainment media. He decided along with certain others to organize a corporation for the purpose of producing a single motion picture starring himself. The…
1Opinion of the Court
OPINION.
Fisher, Judge:
Petitioner contends that his loss upon a loan to Marston, which became worthless in 1949, constitutes a business bad debt, while respondent has determined that the loss incurred was from a nonbusiness bad debt. The ultimate issue is whether the loss resulting from the acknowledged bad debt was proximately related to the conduct of petitioner’s business as an entertainer.
Under section 23 (k) (1), a bad debt incurred in a trade or business is deductible in full in the taxable year in which it becomes worthless, while all other bad debts constitute nonbusiness bad debts and…
2Cases cited12 opinions
- Burnet v. ClarkSupreme Court of the United States · 1932
- Dalton v. BowersSupreme Court of the United States · 1932
- Dallmeyer v. CommissionerUnited States Tax Court · 1950
- Campbell v. CommissionerUnited States Tax Court · 1948
- Towers v. CommissionerUnited States Tax Court · 1955
7 more not listed; retrieve them via the Exa API.
3Cited by34 opinions
- Snow v. CommissionerUnited States Tax Court · 1958
- Shinefeld v. CommissionerUnited States Tax Court · 1976
- United States v. H. F. Keeler and Alice H. Keeler, His WifeCourt of Appeals for the Ninth Circuit · 1962
- Koppelman v. CommissionerUnited States Tax Court · 1956
- Edmund Thomas Gulledge, Sr., and Lucy Coulter Gulledge, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
29 more not listed; retrieve them via the Exa API.