Dennett v. Commissioner
United States Board of Tax Appeals
1. In 1930 each of the petitioners sold to the other certain shares of stock of the General Capital Corporation at a price less than cost. Held, that the petitioners are entitled to deduct from gross income losses sustained upon the sales. 2. In 1930 petitioner Marie G. Dennett was the owner of certain bonds which became worthless in that year. Held, that the investment in such bonds is a deductible loss of the year 1930.
1Opinion of the Court
*56OPINION.
Smith:
In these proceedings the petitioners claim the deduction from gross income of 1930 of losses alleged to have been sustained by each of them upon the sale of securities to the other. The respondent has disallowed the losses upon the ground that under the laws of Massachusetts there can be no valid sale of property between husband and wife. We think there is no merit in this position. We so held in a memorandum opinion entered April 20, 1932, in the case of Richard W. Kale, which was affirmed by the United States Circuit Court of Appeals for the First Circuit in Commissioner v.…
2Cases cited5 opinions
- Duggan v. WrightMassachusetts Supreme Judicial Court · 1892
- Donander Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Peters v. CommissionerUnited States Board of Tax Appeals · 1933
- Springfield Institution for Savings v. CopelandMassachusetts Supreme Judicial Court · 1894
- Riley v. CommissionerUnited States Board of Tax Appeals · 1933
3Cited by1 opinion
- Dennett v. CommissionerUnited States Board of Tax Appeals · 1934