Nippert v. Commissioner
United States Board of Tax Appeals
Over a period of years the decedent paid $373,714.59 for stock and bonds of, and in advances and loans to a corporation. In 1928 he sold all his interest in and claims against the corporation for $80,000. Held, that the stock was worthless prior to 1928; held, further, that decedent's loss is the difference between the total cost of the bonds and advances, and the selling price.
1Opinion of the Court
*894OPINION.
Turnee :
The petitioners take the position that the decedent had a net cash investment, including bonds, stock, judgment, and advances, in the Cincinnati & Westwood Eailroad Co. in the amount *895of $373,714.59, which he sold in 1928 for $80,000, thereby sustaining a loss of $293,714.59. This loss they claim as an allowable deduction for that year under the provisions of section 23 (e)1 of the Revenue Act of 1928.
The respondent has determined that the decedent’s stock and all claims against the Company, exclusive of the bonds, were worthless prior to 1928 and that neither the cost of the…
2Cases cited1 opinion
- Weiss v. WeinerSupreme Court of the United States · 1929
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- Portuguese-American Tin Co. v. CommissionerUnited States Tax Court · 1943
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