Legal Opinion
Pierre Godart and Suzanne Godart v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided February 16, 1970No. 383, Docket 33950PublishedCited by 29 opinions
1Opinion of the Court
FRIENDLY, Circuit Judge:
This petition to review a decision of the Tax Court raises a close question concerning the interpretation of § 1244 of the Internal Revenue Code of 1954, which provides that up to certain maxi-ma, a loss on “§ 1244 stock” is deductible as an ordinary rather than a capital loss. The sole issue is whether certain of the taxpayers’ stock satisfied the requirements of § 1244(c) 1 and the Commissioner’s regulations thereunder. 2
On October 25, 1960 the taxpayer, Pierre Godart, TSM Corporation of which he was president and sole stockholder, and S. Stroock & Co., Inc. entered…
2Cases cited4 opinions
- Godart v. CommissionerUnited States Tax Court · 1969
- Mance T. Spillers and Mary J. Spillers v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1969
- Sofie Eger v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1968
- Henry A. Childs and Carol M. Childs v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1969
3Cited by29 opinions
- Malinowski v. CommissionerUnited States Tax Court · 1979
- John H. Rickey and Lorraine C. Rickey v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1974
- Rickey v. CommissionerUnited States Tax Court · 1970
- Frantz v. CommissionerUnited States Tax Court · 1984
- Leroy Frantz, Jr. And Sheila Frantz v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1986
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