Bloomfield v. Commissioner
United States Tax Court
Petitioner claimed a net operating loss of the alleged net worth of a sole proprietorship as a result of bankruptcy proceedings instituted by him in 1963, the assets of the business having been sold by the referee in bankruptcy and the sale having been confirmed in that year.
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Petitioner claimed a net operating loss of the alleged net worth of a sole proprietorship as a result of bankruptcy proceedings instituted by him in 1963, the assets of the business having been sold by the referee in bankruptcy and the sale having been confirmed in that year. Petitioner and his former wife filed separate returns for 1963 and joint returns for 1960, 1961, and 1962. Each filed for and received refunds based upon the tentative carryback of one-half of the claimed 1963 loss to the earlier years. Held, the right to carry back the claimed net operating loss passed to the trustee in…
1Opinion of the Court
Norris Bloomfield, Petitioner v. Commissioner of Internal Revenue, Respondent
Bloomfield v. Commissioner
Docket No. 2864-67
United States Tax Court
52 T.C. 745; 1969 U.S. Tax Ct. LEXIS 84;
August 4, 1969, Filed
Decision will be entered for the respondent.
Petitioner claimed a net operating loss of the alleged net worth of a sole proprietorship as a result of bankruptcy proceedings instituted by him in 1963, the assets of the business having been sold by the referee in bankruptcy and the sale having been confirmed in that year. Petitioner and his former wife filed separate returns for 1963 and joint…
2Cases cited27 opinions
- Segal v. RochelleSupreme Court of the United States · 1966
- Nicholas v. United StatesSupreme Court of the United States · 1966
- United States v. Skelly Oil Co.Supreme Court of the United States · 1969
- Norene R. O'Dell v. United States of America and Jack Ruhter, Trustee in BankruptcyCourt of Appeals for the Tenth Circuit · 1964
- Richard Douglas Furnish and Emilie Furnish Funk v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
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