Legal Opinion
Fox v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided July 2, 1951No. 21889_1PublishedCited by 34 opinions
1Opinion of the Court
CLARK, Circuit Judge.
Agnes I. Fox, the taxpayer and petitioner for review, in 1935 entered into a written guaranty of certain debts of her husband and now seeks to deduct as a loss from her 1944 income the sum of $15,000 paid by her on the guaranty in that year. The Tax Court treated the payment as a “non-business” bad debt, subject to deduction only to the extent of a short-term capital loss, viz., $1,156.25. 14 T.C. 1160 (one judge dissenting). We agree with the taxpayer, however, that she has brought herself within the statutory definition of a loss from a “transaction entered into for…
2Cases cited13 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Heiner v. TindleSupreme Court of the United States · 1928
- Dresser v. United StatesUnited States Court of Claims · 1932
- Weir v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1940
8 more not listed; retrieve them via the Exa API.
3Cited by34 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- James E. Austin and Elizabeth G. Austin v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- Ewing v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
- Stamos v. CommissionerUnited States Tax Court · 1954
- Martin v. CommissionerUnited States Tax Court · 1969
29 more not listed; retrieve them via the Exa API.