Corey v. Commissioner
United States Tax Court
Petitioners sustained a loss as a consequence of abandonment of their sublessee's interest in the permanent improvements affixed to leased business realty, which loss they characterize "accelerated amortization." Held, that such loss is not attributable to the operation of petitioners' business "regularly carried on" within the meaning of section 122 (d) (5), I. R. C. 1939, and cannot therefore be carried forward to the year 1953 as a net operating loss deduction.
1Opinion of the Court
Gus Corey and Helen Corey, Petitioners, v. Commissioner of Internal Revenue, Respondent
Corey v. Commissioner
Docket No. 57238
United States Tax Court
29 T.C. 360; 1957 U.S. Tax Ct. LEXIS 31; 29 T.C. No. 39;
November 26, 1957, Filed
Decision will be entered under Rule 50.
Petitioners sustained a loss as a consequence of abandonment of their sublessee's interest in the permanent improvements affixed to leased business realty, which loss they characterize "accelerated amortization." Held, that such loss is not attributable to the operation of petitioners' business "regularly carried on" within the…
2Cases cited13 opinions
- Dalton v. BowersSupreme Court of the United States · 1932
- Sic v. CommissionerUnited States Tax Court · 1948
- Lazier v. United StatesCourt of Appeals for the Eighth Circuit · 1948
- Sic v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1949
- Baruch v. CommissionerUnited States Tax Court · 1948
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