Hess v. Commissioner
United States Tax Court
An amount paid by the petitioner in the taxable year in part satisfaction of a guarantee given to his sister against loss of an investment in stock purchased from him, held deductible under section 23 (e) (2), I. R. C.
1Opinion of the Court
OPINION.
Tyson, Judge-.
The sole issue here is whether the petitioner should be allowed to deduct the $1,100 which he paid to Reta H. Lerner in 1941. The petitioner claims the deduction under section 23 (e) of the Internal Bevenue Code,1 and contends that that amount, having been paid pursuant to the guaranty made in connection with the sale of his own stock, constitutes a loss incurred either in trade or business, or in a transaction entered into for profit though not connected with the trade or business. He relies upon R. W. Hale, 32 B. T. A. 356; affirmed on another point, 85 Fed. (2d) 819;…
2Cases cited5 opinions
- Brashears v. CombsCourt of Appeals of Kentucky · 1917
- Griel & Bro. v. SolomonSupreme Court of Alabama · 1886
- Torry v. KraussSupreme Court of Alabama · 1907
- Dantzler v. ScheuerSupreme Court of Alabama · 1919
- Kraus v. TorrySupreme Court of Alabama · 1906
3Cited by13 opinions
- Stamos v. CommissionerUnited States Tax Court · 1954
- United States v. H. F. Keeler and Alice H. Keeler, His WifeCourt of Appeals for the Ninth Circuit · 1962
- Fox v. CommissionerUnited States Tax Court · 1950
- Greenspon v. CommissionerUnited States Tax Court · 1947
- Wakelee v. CommissionerUnited States Tax Court · 1951
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