Horne v. Commissioner
United States Tax Court
Loss deduction claimed on sale of membership certificate in the New York Coffee and Sugar Exchange, Inc., disallowed where eight days previously the holder had purchased another certificate in contemplation of the sale of his old certificate for the purpose of establishing a tax loss deduction.
1Opinion of the Court
OPINION.
Smith, Judge:
This proceeding involves a deficiency of $3,450 in petitioner’s income tax for 1941. The only question in issue is whether petitioner is entitled to a loss deduction on the sale of a membership certificate in the New York Coffee and Sugar Exchange, Inc.
The proceeding was submitted on the following stipulation of facts:
1. Petitioner, Frederick R. Horne, is a resident of the City and State of New York, and filed his income tax return for the calendar year 1941 with the Collector of Internal Revenue, Second New York District. He has been in the commodity import and export…
2Cases cited2 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- In re WaldsteinNew York Supreme Court · 1936
3Cited by29 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Smith v. CommissionerUnited States Tax Court · 1982
- Perry v. CommissionerUnited States Tax Court · 1970
- Koch v. CommissionerUnited States Tax Court · 1978
- Gantner v. CommissionerUnited States Tax Court · 1988
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