Legal Opinion

MacDonald v. Commissioner

United States Board of Tax Appeals

Decided June 8, 1934No. Docket Nos. 55905, 64264Published

1. Petitioner purchased certain shares of corporate stock under a deferred payment contract, and thereafter purported to sell a portion of the stock to various so-called purchasers under separate but similar contracts, conditioned upon the petitioner's carrying out the contract with his vendor. Petitioner retained title to the stock, with all rights of ownership.

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1. Petitioner purchased certain shares of corporate stock under a deferred payment contract, and thereafter purported to sell a portion of the stock to various so-called purchasers under separate but similar contracts, conditioned upon the petitioner's carrying out the contract with his vendor. Petitioner retained title to the stock, with all rights of ownership. Held, petitioner is not entitled to deduct losses alleged to have been sutained in such transactions. 2. The deferred payment contract by which petitioner acquired the stock referred to the purchase price as being $322,250 and stated…

1Opinion of the Court

GEORGE S. MACDONALD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

MacDonald v. Commissioner

Docket Nos. 55905, 64264.

United States Board of Tax Appeals

30 B.T.A. 884; 1934 BTA LEXIS 1250;

June 8, 1934, Promulgated

1. Petitioner purchased certain shares of corporate stock under a deferred payment contract, and thereafter purported to sell a portion of the stock to various so-called purchasers under separate but similar contracts, conditioned upon the petitioner's carrying out the contract with his vendor. Petitioner retained title to the stock, with all rights of ownership. Held,…

2Cases cited1 opinion

  1. MacDonald v. CommissionerUnited States Board of Tax Appeals · 1934

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