Torodor v. Commissioner
United States Tax Court
In 1947, Rogers Utilities, Inc., sold its business to a competitor including approximately 2,700 accounts receivable. These accounts receivable were sold for $ 32,672.34 less than their face value. Petitioner on its return claimed a loss of $ 32,672.34, deductible in full. The Commissioner in his determination of the deficiency has treated the loss as a capital loss limited to the extent provided in section 117 (d) (1) of the Code.
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In 1947, Rogers Utilities, Inc., sold its business to a competitor including approximately 2,700 accounts receivable. These accounts receivable were sold for $ 32,672.34 less than their face value. Petitioner on its return claimed a loss of $ 32,672.34, deductible in full. The Commissioner in his determination of the deficiency has treated the loss as a capital loss limited to the extent provided in section 117 (d) (1) of the Code. Held, following Graham Mill & Elevator Co. v. Thomas, 152 F. 2d 564, the Commissioner is sustained.
1Opinion of the Court
Max Torodor and Sarah Torodor, Petitioners, v. Commissioner of Internal Revenue, Respondent. Rogers Utilities, Inc., a Dissolved Corporation, c/o Max Torodor, Petitioner, v. Commissioner of Internal Revenue, Respondent
Torodor v. Commissioner
Docket Nos. 32109, 32110
United States Tax Court
19 T.C. 530; 1952 U.S. Tax Ct. LEXIS 12;
December 24, 1952, Promulgated
Decisions will be entered for the respondent.
In 1947, Rogers Utilities, Inc., sold its business to a competitor including approximately 2,700 accounts receivable. These accounts receivable were sold for $ 32,672.34 less than their face…
2Cases cited2 opinions
- Graham Mill & Elevator Co. v. ThomasCourt of Appeals for the Fifth Circuit · 1945
- Torodor v. CommissionerUnited States Tax Court · 1952