Pollack v. Commissioner
United States Tax Court
Petitioner, a management consultant, purchased an interest in Millworth, a limited partnership, to secure a new source of potential consulting business. When the anticipated consulting business failed to materialize, petitioner disposed of his interest at a loss. Held, sec. 741, I.R.C. 1954, is dispositive of the character of petitioner's loss; petitioner therefore sustained a capital loss on the disposition of his partnership interest.
1Opinion of the Court
H. Clinton Pollack, Jr., and Wendy Pollack, Petitioners v. Commissioner of Internal Revenue, Respondent
Pollack v. Commissioner
Docket No. 3049-74
United States Tax Court
69 T.C. 142; 1977 U.S. Tax Ct. LEXIS 31;
October 27, 1977, Filed
Decision will be entered for the respondent.
Petitioner, a management consultant, purchased an interest in Millworth, a limited partnership, to secure a new source of potential consulting business. When the anticipated consulting business failed to materialize, petitioner disposed of his interest at a loss. Held, sec. 741, I.R.C. 1954, is dispositive of the character…
Also in this document: Dissent · Tannenwald; Dissent · Tannenwald.
2Cases cited14 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Helvering v. William Flaccus Oak Leather Co.Supreme Court of the United States · 1941
- W. W. Windle Co. v. CommissionerUnited States Tax Court · 1976
- Estate of Munter v. CommissionerUnited States Tax Court · 1975
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