Wiggin v. Commissioner
United States Board of Tax Appeals
Where the principal stockholder of a corporation enters into an agreement with the corporation to serve it as president upon the basis that the net profits of the corporation shall be paid to him as compensation and the net losses of the corporation shall be sustained by such principal stockholder, and net losses are sustained, such net losses are not deductible from gross income in the individual's income-tax returns.
1Opinion of the Court
*286OPINION.
Smith:
The sole question presented by these proceedings is the right of the petitioner to deduct from gross income in his income-tax returns for the years 1922 to 1925, inclusive, the net losses of the H. H. Wiggin Lumber Co., which the petitioner was required to make good and did make good to the H. H. Wiggin Lumber Co. under his agreements with that company. The petitioner claims the deductions as losses sustained by him under the provisions of section 214(a) of the Revenue Acts of 1921,1924, and 1926, which provide, in so far as material, as follows:(a) That in computing net income…
2Cited by2 opinions
- Haas v. CommissionerUnited States Tax Court · 1959
- Wiggin v. CommissionerUnited States Board of Tax Appeals · 1930