Burnett v. Commissioner
United States Board of Tax Appeals
1. During the taxable year 1934 petitioner was carrying on the trade or business of purchasing and selling securities and commodities for her own account through brokers on margin accounts and incurred a loss of $18,964.21 in such tradings.
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1. During the taxable year 1934 petitioner was carrying on the trade or business of purchasing and selling securities and commodities for her own account through brokers on margin accounts and incurred a loss of $18,964.21 in such tradings. Held, the securities and commodities which petitioner thus purchased and sold "were not property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business" as provided by section 117(b), Revenue Act of 1934, and the limitation of capital loss provisions of section 117(d) of the 1934 Act applies. Charles Wesley…
1Opinion of the Court
O. L. BURNETT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Burnett v. Commissioner
Docket No. 90248.
United States Board of Tax Appeals
40 B.T.A. 605; 1939 BTA LEXIS 828;
September 29, 1939, Promulgated
1. During the taxable year 1934 petitioner was carrying on the trade or business of purchasing and selling securities and commodities for her own account through brokers on margin accounts and incurred a loss of $18,964.21 in such tradings. Held, the securities and commodities which petitioner thus purchased and sold "were not property held by the taxpayer primarily for sale to…
2Cases cited3 opinions
- Burnett v. CommissionerUnited States Board of Tax Appeals · 1939
- Slack v. CommissionerUnited States Board of Tax Appeals · 1937
- Purdy v. CommissionerUnited States Board of Tax Appeals · 1937