Abdalla v. Commissioner
United States Tax Court
Held: Petitioner is entitled to a deduction for his pro rata share of two subch. S corporations' net operating losses. Because petitioner's stock basis and basis of indebtedness became worthless as of Oct. 26, 1966, his share of such losses is computed for that part of the corporations' taxable year ending Oct. 25, 1966. Held, further, interest payments made in connection with a bad debt are colored thereby, giving rise to a sec. 166 bad debt loss.
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Held: Petitioner is entitled to a deduction for his pro rata share of two subch. S corporations' net operating losses. Because petitioner's stock basis and basis of indebtedness became worthless as of Oct. 26, 1966, his share of such losses is computed for that part of the corporations' taxable year ending Oct. 25, 1966. Held, further, interest payments made in connection with a bad debt are colored thereby, giving rise to a sec. 166 bad debt loss. Held, further, petitioner's basis for the purpose of computing gain realized on the liquidation of two other corporations is not increased due to…
1Opinion of the Court
Jacob Abdalla and Mary T. Abdalla, Petitioners v. Commissioner of Internal Revenue, Respondent
Abdalla v. Commissioner
Docket No. 1783-74
United States Tax Court
69 T.C. 697; 1978 U.S. Tax Ct. LEXIS 182;
February 13, 1978, Filed
Decision will be entered under Rule 155.
Held: Petitioner is entitled to a deduction for his pro rata share of two subch. S corporations' net operating losses. Because petitioner's stock basis and basis of indebtedness became worthless as of Oct. 26, 1966, his share of such losses is computed for that part of the corporations' taxable year ending Oct. 25, 1966. Held,…
Also in this document: Dissent · Hall; Dissent · Wiles.
2Cases cited21 opinions
- Markham v. CabellSupreme Court of the United States · 1946
- Boehm v. CommissionerSupreme Court of the United States · 1945
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Helvering v. William Flaccus Oak Leather Co.Supreme Court of the United States · 1941
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