Smith v. Commissioner
United States Tax Court
Petitioner withdrew his interest in a joint account operated by himself, his mother, and his two sisters as a joint venture, receiving cash equivalent to his undivided interest in the assets in the account. Held, that the transaction was tantamount to a sale by petitioner to the other participants of his interest in assets in the joint account and that the loss thereon is nondeductible under the provisions of section 24 (b) (1) (A), Internal Revenue Code.
1Opinion of the Court
OPINION.
Smith, Judge:
The respondent determined a deficiency in petitioner’s income tax for 1941 in the amount of $1,458.41. The petitioner alleges that the respondent erred in his determination by disallowing the deduction of $9,722.71 claimed to represent a loss sustained by him on the liquidation of his interest in a joint account which had been operated by him and his mother and his two sisters.
The facts have been stipulated.
The petitioner is a resident of New Canaan, Connecticut. He filed his income tax return for the year 1941 with the collector of internal revenue for the third district…
2Cases cited1 opinion
- Bull v. United StatesSupreme Court of the United States · 1935
3Cited by7 opinions
- Ford v. Comm'rUnited States Tax Court · 1946
- Blum v. CommissionerUnited States Tax Court · 1945
- H. N. Miller v. The United StatesUnited States Court of Claims · 1964
- Blum v. CommissionerUnited States Tax Court · 1945
- Blum v. CommissionerUnited States Tax Court · 1945
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