Montgomery v. Commissioner
United States Board of Tax Appeals
1. Where the petitioner, who operated a garage and automobile sales agency, purchased stock of an automobile manufacturing company in order to acquire an agency contract, which stock later became worthless, held that the loss thus sustained should be included in the computation of a net loss under section 204(a) of the Revenue Act of 1921. Philip Kobbe Co.,4 B.T.A. 663, followed. 2. The net loss provided for in section 204 means only net losses resulting from the operation…
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1. Where the petitioner, who operated a garage and automobile sales agency, purchased stock of an automobile manufacturing company in order to acquire an agency contract, which stock later became worthless, held that the loss thus sustained should be included in the computation of a net loss under section 204(a) of the Revenue Act of 1921. Philip Kobbe Co.,4 B.T.A. 663, followed. 2. The net loss provided for in section 204 means only net losses resulting from the operation of a trade or business regularly carried on by a taxpayer. A net loss so resulting may not be increased by nonbusiness…
1Opinion of the Court
LAWRENCE J. MONTGOMERY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Montgomery v. Commissioner
Docket No. 28583.
United States Board of Tax Appeals
17 B.T.A. 1308; 1929 BTA LEXIS 2150;
November 7, 1929, Promulgated
1. Where the petitioner, who operated a garage and automobile sales agency, purchased stock of an automobile manufacturing company in order to acquire an agency contract, which stock later became worthless, held that the loss thus sustained should be included in the computation of a net loss under section 204(a) of the Revenue Act of 1921. Philip Kobbe Co.,4 B.T.A. 663,…
2Cases cited3 opinions
- Schlesinger v. CommissionerUnited States Board of Tax Appeals · 1926
- Montgomery v. CommissionerUnited States Board of Tax Appeals · 1929
- Appeal of Philip Kobbe Co.United States Board of Tax Appeals · 1926