Hotz v. Commissioner
United States Board of Tax Appeals
A taxpayer with others as joint venturers purchased a farm subject to mortgage; after the mortgagee had bid in the property at a foreclosure sale and during the period of redemption the taxpayer paid the redemption money to the mortgagee, received the Master's certificate, and after expiration of the redemption period in 1936 received a deed from the Master. Held, the taxpayer is not entitled to a loss deduction in 1936.
1Opinion of the Court
OPINION.
StjsrnhageN :
The Commissioner determined a deficiency of $515.99 in petitioners’ income tax for 1936. He disallowed several deductions taken by the petitioners on their joint return. None of these is now in issue. The only issue is as to the right of Clothilde Hotz, hereinafter called the petitioner, to a deduction in 1936, not taken on the return and hence not mentioned in the deficiency notice, for loss in respect of a real estate venture which originated in 1924. The facts have all been stipulated and are hereby found as stipulated.
In December of 1924 Ferdinand Hotz, as agent for…
2Cases cited5 opinions
- Hooper v. GoldsteinIllinois Supreme Court · 1929
- Herdman v. CooperIllinois Supreme Court · 1891
- Lomax v. GindeleIllinois Supreme Court · 1886
- Boynton v. PierceIllinois Supreme Court · 1894
- Keller v. ComanIllinois Supreme Court · 1896
3Cited by1 opinion
- Hotz v. CommissionerUnited States Board of Tax Appeals · 1940