Bradford v. Commissioner
United States Tax Court
1. A dealer in securities realized a gain upon the sale of certain stocks to its customers in the ordinary course of its dealer business. Held, the gain constituted ordinary income rather than a capital gain. 2. Petitioner was released from his liability as endorser of a note upon part payment of the amount due. The creditor retained the note upon which there was an unpaid balance.
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1. A dealer in securities realized a gain upon the sale of certain stocks to its customers in the ordinary course of its dealer business. Held, the gain constituted ordinary income rather than a capital gain. 2. Petitioner was released from his liability as endorser of a note upon part payment of the amount due. The creditor retained the note upon which there was an unpaid balance. Held, petitioner did not become subrogated to the rights of the creditor under Tennessee law, and the payment was not deductible as a worthless bad debt. The payment was deductible, however, as loss within the…
1Opinion of the Court
J. C. Bradford, Petitioner, v. Commissioner of Internal Revenue, Respondent. Eleanor A. Bradford, Petitioner, v. Commissioner of Internal Revenue, Respondent
Bradford v. Commissioner
Docket Nos. 35990, 36895
United States Tax Court
22 T.C. 1057; 1954 U.S. Tax Ct. LEXIS 123;
August 18, 1954, Filed August 18, 1954, Filed
Decisions will be entered under Rule 50.
1. A dealer in securities realized a gain upon the sale of certain stocks to its customers in the ordinary course of its dealer business. Held, the gain constituted ordinary income rather than a capital gain.
2. Petitioner was released from his…
2Cases cited29 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Helvering v. CliffordSupreme Court of the United States · 1940
- Higgins v. SmithSupreme Court of the United States · 1940
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Burnet v. LoganSupreme Court of the United States · 1931
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