Engelhart v. Commissioner
United States Tax Court
Losses -- Sales to Controlled Corporation -- Sec. 24 (b) (1). -- The petitioner made separate purchases of "mixed metal" during 1950. He held the metal first purchased for more than 6 months and the second for less than 6 months. He sold both lots in 1951, that held for more than 6 months at a gain and that held for less than 6 months at a loss. Each sale was to a corporation, more than 50 per cent of the stock of which was owned by the petitioner and his wife.
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Losses -- Sales to Controlled Corporation -- Sec. 24 (b) (1). -- The petitioner made separate purchases of "mixed metal" during 1950. He held the metal first purchased for more than 6 months and the second for less than 6 months. He sold both lots in 1951, that held for more than 6 months at a gain and that held for less than 6 months at a loss. Each sale was to a corporation, more than 50 per cent of the stock of which was owned by the petitioner and his wife. Section 24 (b) (1) applies and the petitioner is not entitled to deduct the loss or to offset it against the gain which exceeded the…
1Opinion of the Court
Frank C. Engelhart and Nina Engelhart, Petitioners, v. Commissioner of Internal Revenue, Respondent
Engelhart v. Commissioner
Docket No. 61114
United States Tax Court
30 T.C. 1013; 1958 U.S. Tax Ct. LEXIS 118;
July 31, 1958, Filed
Decision will be entered for the respondent.
Losses -- Sales to Controlled Corporation -- Sec. 24 (b) (1). -- The petitioner made separate purchases of "mixed metal" during 1950. He held the metal first purchased for more than 6 months and the second for less than 6 months. He sold both lots in 1951, that held for more than 6 months at a gain and that held for less than 6…
2Cases cited11 opinions
- Kaplan v. CommissionerUnited States Tax Court · 1953
- W. A. Drake, Inc. v. CommissionerUnited States Tax Court · 1944
- WA Drake, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Tenth Circuit · 1944
- Lakeside Irr. Co. v. Commissioner of Internal Rev.Court of Appeals for the Fifth Circuit · 1942
- M. F. Reddington Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1942
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