Legal Opinion
Janney v. Commissioner
Court of Appeals for the Third Circuit
Decided December 26, 1939No. 7130PublishedCited by 2 opinions
1Opinion of the Court
BIDDLE, Circuit Judge.
The petitioners were married and living together in 1934. Mrs. Janney realized gains and Mr. Janney losses (in that year on the sale of capital assets. They filed a joint income tax return in which the losses were used to offset the gains. Except to the extent of $2,000 the Commissioner of Internal Revenue disallowed all the losses, on the ground that the losses of one spouse could not be set off against the gains of the other. The Board of Tax Appeals sustained the Commissioner, and this appeal followed.
The statutory provisions involved are found in the Revenue Act of…
2Cases cited15 opinions
- Hassett v. WelchSupreme Court of the United States · 1938
- Helvering v. WinmillSupreme Court of the United States · 1938
- Iselin v. United StatesSupreme Court of the United States · 1926
- New York, New Haven & Hartford Railroad v. Interstate Commerce CommissionSupreme Court of the United States · 1906
- Helvering v. New York Trust Co.Supreme Court of the United States · 1934
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3Cited by2 opinions
- Helvering v. JanneySupreme Court of the United States · 1940
- Aluminum Co. of America v. United StatesCourt of Appeals for the Third Circuit · 1941