Collins v. Commissioner
United States Tax Court
Petitioner's ownership and operation of the Boston Yanks and the New York Bulldogs, professional football teams, under different franchises and in different but successive years, held, to constitute separate business within the meaning of section 130, I.R.C. 1939, and losses of the Yanks cannot be tacked on to losses of the Bulldogs and its successor to permit disallowance of losses in excess of $ 50,000 attributable to a trade or business carried on for 5 consecutive years…
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Petitioner's ownership and operation of the Boston Yanks and the New York Bulldogs, professional football teams, under different franchises and in different but successive years, held, to constitute separate business within the meaning of section 130, I.R.C. 1939, and losses of the Yanks cannot be tacked on to losses of the Bulldogs and its successor to permit disallowance of losses in excess of $ 50,000 attributable to a trade or business carried on for 5 consecutive years under section 130.
1Opinion of the Court
Joseph M. Collins, Petitioner, v. Commissioner of Internal Revenue, Respondent
Collins v. Commissioner
Docket Nos. 69165, 69166
United States Tax Court
34 T.C. 592; 1960 U.S. Tax Ct. LEXIS 120;
June 27, 1960, Filed
Decisions will be entered under Rule 50.
Petitioner's ownership and operation of the Boston Yanks and the New York Bulldogs, professional football teams, under different franchises and in different but successive years, held, to constitute separate business within the meaning of section 130, I.R.C. 1939, and losses of the Yanks cannot be tacked on to losses of the Bulldogs and its…
2Cases cited2 opinions
- Davis v. CommissionerUnited States Tax Court · 1958
- Collins v. CommissionerUnited States Tax Court · 1960