Legal Opinion

Putnam v. Commissioner

United States Board of Tax Appeals

Decided October 3, 1934No. Docket No. 64282Published

Petitioner's husband, the owner of certain corporate notes aggregating $142,000, gave to petitioner $72,000 thereof in 1928, which she sold for $1 and obtained a deduction accordingly in her income tax for that year.

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Petitioner's husband, the owner of certain corporate notes aggregating $142,000, gave to petitioner $72,000 thereof in 1928, which she sold for $1 and obtained a deduction accordingly in her income tax for that year. In 1929, the taxable year, the husband, to obtain a like result, gave to petitioner the remaining $70,000 of the notes, which she likewise sold for $1. Held, the claim by petitioner for a deductible loss for 1929 on this account is cognizable only under the worthless debt provisions of the statute, and, as the notes were ascertained to be worthless in 1928, the respondent…

1Opinion of the Court

KATHARINE H. PUTNAM, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Putnam v. Commissioner

Docket No. 64282.

United States Board of Tax Appeals

31 B.T.A. 241; 1934 BTA LEXIS 1128;

October 3, 1934, Promulgated

Petitioner's husband, the owner of certain corporate notes aggregating $142,000, gave to petitioner $72,000 thereof in 1928, which she sold for $1 and obtained a deduction accordingly in her income tax for that year. In 1929, the taxable year, the husband, to obtain a like result, gave to petitioner the remaining $70,000 of the notes, which she likewise sold for $1. Held, the…

2Cases cited1 opinion

  1. Putnam v. CommissionerUnited States Board of Tax Appeals · 1934

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