Legal Opinion

Hedrick v. Commissioner

United States Board of Tax Appeals

Decided July 18, 1930No. Docket No. 43331Published

In 1923 the petitioner was president and general manager of a construction company of which he owned 80 per cent of the capital stock. The corporation became insolvent and was dissolved in 1924, the petitioner losing his investment therein. held that the loss sustained was not a loss "resulting from the operation of any trade or business regularly carried on by the taxpayer" within the provisions of section 204(a) of the Revenue Act of 1921.

1Opinion of the Court

WYATT C. HEDRICK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Hedrick v. Commissioner

Docket No. 43331.

United States Board of Tax Appeals

20 B.T.A. 258; 1930 BTA LEXIS 2169;

July 18, 1930, Promulgated

In 1923 the petitioner was president and general manager of a construction company of which he owned 80 per cent of the capital stock. The corporation became insolvent and was dissolved in 1924, the petitioner losing his investment therein. held that the loss sustained was not a loss "resulting from the operation of any trade or business regularly carried on by the taxpayer" within…

2Cases cited3 opinions

  1. Goldberg v. CommissionerUnited States Board of Tax Appeals · 1928
  2. Montgomery v. CommissionerUnited States Board of Tax Appeals · 1929
  3. Hedrick v. CommissionerUnited States Board of Tax Appeals · 1930

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