Hall v. Commissioner
United States Board of Tax Appeals
Where a partnership, of which petitioners were members, purchased securities for resale to customers at a profit and not for purposes of speculation or investment, and in its books of account regularly inventoried at market unsold securities on hand at the end of each year, and in its tax returns computed net income on the same basis, such partnership was a dealer in securities within the meaning of article 105 of Regulations 74, and petitioners are entitled to have their…
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Where a partnership, of which petitioners were members, purchased securities for resale to customers at a profit and not for purposes of speculation or investment, and in its books of account regularly inventoried at market unsold securities on hand at the end of each year, and in its tax returns computed net income on the same basis, such partnership was a dealer in securities within the meaning of article 105 of Regulations 74, and petitioners are entitled to have their distributive shares of the partnership's net income for the taxable years 1929 and 1930 computed by the use of inventories…
1Opinion of the Court
OPINION.
Tkammell :
The,se are consolidated proceedings for the redeter-mination of deficiencies in income tax as follows:
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All issues raised by the pleadings, except one, were settled by a written stipulation signed by the parties and filed at the hearing, which stipulation is by reference adopted as a part hereof and will *1256be given effect in redetermination of the deficiencies under Bule 50. The sole issue submitted for decision is whether or not the partnership of Stevens & Legg, hereinafter referred to as the partnership, of which the petitioners were members, was entitled to…
2Cases cited4 opinions
- Weinhouse v. CroninSupreme Court of Connecticut · 1896
- Donander Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Oil Shares, Inc. v. CommissionerUnited States Board of Tax Appeals · 1934
- Northeastern Surety Co. v. CommissionerUnited States Board of Tax Appeals · 1933
3Cited by12 opinions
- Squire v. DenmanDistrict Court, N.D. Ohio · 1936
- Currie v. CommissionerUnited States Tax Court · 1969
- Hamill v. CommissionerUnited States Board of Tax Appeals · 1934
- Frankel v. CommissionerUnited States Tax Court · 1989
- Lowell v. CommissionerUnited States Board of Tax Appeals · 1934
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