Mellon v. Commissioner
United States Board of Tax Appeals
1. The sale by petitioner of stock of the Pittsburgh Coal Co. to the Union Trust Co. of Pittsburgh was a complete and valid sale, giving rise to a legal deduction. 2. Respondent disallowed a deduction claimed on account of loss on sale of stock of the Western Public Service Corporation, on the ground that "the disposal of these stocks do not appear to be transactions on which losses may be recognized for income tax purposes."
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1. The sale by petitioner of stock of the Pittsburgh Coal Co. to the Union Trust Co. of Pittsburgh was a complete and valid sale, giving rise to a legal deduction. 2. Respondent disallowed a deduction claimed on account of loss on sale of stock of the Western Public Service Corporation, on the ground that "the disposal of these stocks do not appear to be transactions on which losses may be recognized for income tax purposes." Petitioner in his petition affirmatively alleged that petitioner did not, within "thirty days before or after the date of such sales, enter into any contract or option…
1Opinion of the Court
*1048OPINION.
I.—The Stock Sales.
Van Fossan: The stock transactions described in part I of our findings of fact—specifically, the sale by petitioner of stock of Pittsburgh Coal Co. to the Union Trust Co., the sale by B. B. Mellon on petitioner’s behalf of stock of the Western Public Service Corporation to the Union Trust Co., and the sale by petitioner of stock of five corporations to the Ascalot Co., are the only stock sales under question in this proceeding. The sale of Pittsburgh Coal Co. stock and the sale of stock of the Western Public Service Corporation are the only items against which the…
2Cases cited7 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Burnet v. Commonwealth Improvement Co.Supreme Court of the United States · 1932
- Groman v. CommissionerSupreme Court of the United States · 1937
- Reese v. Philadelphia Trust, Safe Deposit & InsuranceSupreme Court of Pennsylvania · 1907
- Thompson's EstateSupreme Court of Pennsylvania · 1924
2 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Skripak v. CommissionerUnited States Tax Court · 1985
- Lash v. CommissionerUnited States Tax Court · 1956
- Specialty Paper & Board Co. v. CommissionerUnited States Tax Court · 1965
- Bennett v. CommissionerUnited States Tax Court · 1991
- Burnette v. CommissionerUnited States Tax Court · 1959
23 more not listed; retrieve them via the Exa API.