Elliott v. Commissioner
United States Board of Tax Appeals
NET LOSSES FROM TRADE OR BUSINESS. - It is shown that transactions of the petitioner in buying and selling cotton futures and corporate stocks occupied 75 per cent of his business hours, and they were sufficiently regular and numerous to amount to a business; therefore, the losses resulting and paid in cash are "net losses" subject to the provisions of section 204 of the Revenue Act of 1921.
1Opinion of the Court
E. M. ELLIOTT, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Elliott v. Commissioner
Docket No. 16693.
United States Board of Tax Appeals
15 B.T.A. 494; 1929 BTA LEXIS 2848;
February 19, 1929, Promulgated
NET LOSSES FROM TRADE OR BUSINESS. - It is shown that transactions of the petitioner in buying and selling cotton futures and corporate stocks occupied 75 per cent of his business hours, and they were sufficiently regular and numerous to amount to a business; therefore, the losses resulting and paid in cash are "net losses" subject to the provisions of section 204 of the Revenue Act…
2Cases cited12 opinions
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Von Baumbach v. Sargent Land Co.Supreme Court of the United States · 1917
- The Parker Mills v. . the Commissioners of TaxesNew York Court of Appeals · 1861
- Mente v. EisnerCourt of Appeals for the Second Circuit · 1920
- Lederer v. CadwaladerCourt of Appeals for the Third Circuit · 1921
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