Legal Opinion

Bullock v. Commissioner

United States Board of Tax Appeals

Decided June 15, 1931No. Docket No. 31209Published

1. Where petitioner in 1913 acquired stock in a corporation which he in 1923 exchanged for stock in another corporation on which transaction neither a gain nor loss was recognizable under the statute, and in 1924 sold at a loss part of the stock acquired in 1923, the loss is not a "capital net loss" under the provisions of section 208 of the Revenue Act of 1924, the new stock not having been held for more than two years. 2. Loss from the sale of real estate originally…

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1. Where petitioner in 1913 acquired stock in a corporation which he in 1923 exchanged for stock in another corporation on which transaction neither a gain nor loss was recognizable under the statute, and in 1924 sold at a loss part of the stock acquired in 1923, the loss is not a "capital net loss" under the provisions of section 208 of the Revenue Act of 1924, the new stock not having been held for more than two years. 2. Loss from the sale of real estate originally acquired as a residence and later converted into business property determined.

1Opinion of the Court

GEORGE BULLOCK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Bullock v. Commissioner

Docket No. 31209.

United States Board of Tax Appeals

23 B.T.A. 710; 1931 BTA LEXIS 1836;

June 15, 1931, Promulgated

1. Where petitioner in 1913 acquired stock in a corporation which he in 1923 exchanged for stock in another corporation on which transaction neither a gain nor loss was recognizable under the statute, and in 1924 sold at a loss part of the stock acquired in 1923, the loss is not a "capital net loss" under the provisions of section 208 of the Revenue Act of 1924, the new stock not…

2Cases cited11 opinions

  1. United States v. LudeySupreme Court of the United States · 1927
  2. United States v. FlannerySupreme Court of the United States · 1925
  3. Marr v. United StatesSupreme Court of the United States · 1925
  4. Heiner v. TindleSupreme Court of the United States · 1928
  5. McCaughn v. LudingtonSupreme Court of the United States · 1925

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