MacDonald v. Commissioner
United States Board of Tax Appeals
1. Petitioner purchased certain shares of corporate stock under a deferred payment contract, and thereafter purported to sell a portion of the stock to various so-called purchasers under separate but similar contracts, conditioned upon the petitioner's carrying out the contract with his vendor. Petitioner retained title to the stock, with all rights of ownership.
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1. Petitioner purchased certain shares of corporate stock under a deferred payment contract, and thereafter purported to sell a portion of the stock to various so-called purchasers under separate but similar contracts, conditioned upon the petitioner's carrying out the contract with his vendor. Petitioner retained title to the stock, with all rights of ownership. Held, petitioner is not entitled to deduct losses alleged to have been sutained in such transactions. 2. The deferred payment contract by which petitioner acquired the stock referred to the purchase price as being $322,250 and stated…
1Opinion of the Court
opinion.
Trammell :
These are proceedings for the redetermination of deficiencies in income tax for 1928 in the amount of $4,023.88 and for 1929 in the amount of $2,334.68. The errors assigned in each of the petitions are (1) the failure of the Commissioner to allow as deductions losses claimed in each of the years from the sale of stock and (2) the failure of the Commissioner to allow as deductions interest alleged to have been paid by the petitioner during the taxable years. The proceedings were consolidated for hearing.
The petitioner is an individual, residing at New Rochelle, New York.
In…
2Cases cited4 opinions
- Erskine v. CommissionerUnited States Board of Tax Appeals · 1932
- Anderson & Co. v. CommissionerUnited States Board of Tax Appeals · 1927
- Daniel Bros. Co. v. CommissionerUnited States Board of Tax Appeals · 1927
- Marsh & Marsh, Inc. v. CommissionerUnited States Board of Tax Appeals · 1926
3Cited by3 opinions
- Field v. CommissionerUnited States Tax Court · 1971
- MacDonald v. CommissionerUnited States Board of Tax Appeals · 1934
- Strange Bros. Hide Co. v. CommissionerUnited States Tax Court · 1943