Cass v. Commissioner
United States Board of Tax Appeals
Respondent disallowed a deduction for loss on sale of stock on the ground of worthlessness of the stock prior to the year of sale. Held, the evidence is insufficient to overcome the presumptive correctness of respondent's determination and the disallowance of the claimed deduction is sustained.
1Opinion of the Court
*716OPINION.
Arundell :
In the notice of deficiency the respondent states that the loss deduction claimed by petitioner “has been disallowed for the reason that this office holds that the stock became worthless prior to 1931.” In a written stipulation of facts filed prior to the hearing, it is stated, “The respondent disallowed this loss on the ground that the stock was worthless prior to 1931.” The one error alleged in the petition for redetermination is the finding of the Commissioner that the stock was worthless prior to 1931. This allegation of error is denied in the respondent’s answer. On…
2Cases cited1 opinion
- Old Mission Portland Cement Co. v. HelveringSupreme Court of the United States · 1934
3Cited by5 opinions
- G. E. Employees Securities Corp. v. ManningDistrict Court, D. New Jersey · 1941
- Bair v. United StatesDistrict Court, E.D. Pennsylvania · 1937
- Brumder v. United StatesDistrict Court, E.D. Wisconsin · 1944
- Cass v. CommissionerUnited States Board of Tax Appeals · 1935
- Rand v. CommissionerUnited States Board of Tax Appeals · 1939