Belser v. Commissioner
United States Tax Court
1. The taxpayer purchased all the shares of a corporation which acquired two farms and he thereafter made loans and advances to the corporation. Prior to 1932 the corporation had divested itself of the farms, retaining no assets, and mortgages on the farms, securing the taxpayer's loans, had been extinguished.
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1. The taxpayer purchased all the shares of a corporation which acquired two farms and he thereafter made loans and advances to the corporation. Prior to 1932 the corporation had divested itself of the farms, retaining no assets, and mortgages on the farms, securing the taxpayer's loans, had been extinguished. The cost of the shares and the amount of the loans, held, not deductible in 1932 because shares and loans became worthless in prior years. 2. The taxpayer, a lawyer, was appointed special counsel for a state railroad commission at an annual salary. He continued his private law practice…
1Opinion of the Court
OPINION.
Johnson, Judge:
1. Petitioner charges the Commissioner with error in failing to allow as a deduction “a loss sustained or bad debt obligations determined to be worthless in the amount of $24,000, due to petitioner’s investments in stock of the Fairview Farming Company and/or indebtedness due to him from the said corporation or growing out of certain real estate transactions involving the purchase of two tracts of land known as DePriest and Stewart tracts.” He computes the $24,000 as follows:
Investment in 200 shares of stock_$14, 400
Loan secured by second mortgage on Stewart tract_ 5,…
2Cases cited7 opinions
- Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
- Graves v. New York Ex Rel. O'KeefeSupreme Court of the United States · 1939
- Helvering v. GerhardtSupreme Court of the United States · 1938
- O'Meara v. CommissionerUnited States Tax Court · 1947
- Yeomans v. CommissionerUnited States Tax Court · 1945
2 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Conlorez Corp. v. CommissionerUnited States Tax Court · 1968
- ABC Bev. Corp. v. Comm'rUnited States Tax Court · 2006
- Hodous v. CommissionerUnited States Tax Court · 1950
- Belser v. CommissionerUnited States Tax Court · 1948
- Conlorez Corp. v. CommissionerUnited States Tax Court · 1968
4 more not listed; retrieve them via the Exa API.