Koppelman v. Commissioner
United States Tax Court
The taxpayers were partners in a beverage distribution business which purchased stock ownership of a brewery in 1946 in order to provide itself with beer which was in short supply that year due to a grain shortage. The partnership and brewery prospered during the shortage in 1946 but both lost money in 1947 when there was no longer a shortage of beer. In 1948 the brewery commenced brewing ale in small bottles for distribution primarily by the partnership.
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The taxpayers were partners in a beverage distribution business which purchased stock ownership of a brewery in 1946 in order to provide itself with beer which was in short supply that year due to a grain shortage. The partnership and brewery prospered during the shortage in 1946 but both lost money in 1947 when there was no longer a shortage of beer. In 1948 the brewery commenced brewing ale in small bottles for distribution primarily by the partnership. The latter advanced money to the brewery corporation to enable it to brew the ale. The small bottles of ale sold well for 3 months but fell…
1Opinion of the Court
Tietjens, Judge:
The Commissioner determined the following deficiencies in the petitioners’ income taxes for the year 1946:
Docket No. Deficiency
$3,408. 77 51067
51068 2, 874. 09
51069 3, 813. 92
These deficiencies arose as a result of the Commissioner’s disallowance of certain portions of 1948 net operating loss carrybacks claimed by each of the petitioners. The bulk of each loss carryback consisted of each petitioner’s share of a bad debt of $42,642.56 allegedly sustained in 1948 by the partnership, in which they were partners, in the ordinary course of its trade or business. The only issue for…
2Cases cited11 opinions
- Burnet v. ClarkSupreme Court of the United States · 1932
- Dalton v. BowersSupreme Court of the United States · 1932
- Campbell v. CommissionerUnited States Tax Court · 1948
- Boissevain v. CommissionerUnited States Tax Court · 1951
- Western Wine & Liquor Co. v. CommissionerUnited States Tax Court · 1952
6 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Pachella v. CommissionerUnited States Tax Court · 1961
- Ferguson v. CommissionerUnited States Tax Court · 1957
- Hudson v. CommissionerUnited States Tax Court · 1958
- Decker v. United StatesDistrict Court, N.D. Iowa · 1965
- Old Dominion Plywood Corp. v. CommissionerUnited States Tax Court · 1966
9 more not listed; retrieve them via the Exa API.