Legal Opinion

Northeastern Surety Co. v. Commissioner

United States Board of Tax Appeals

Decided November 2, 1933No. Docket No. 62624PublishedCited by 6 opinions

Held, that during the taxable year 1929 the petitioner was not a merchant or dealer in securities within the meaning of article 105 of Regulations 74, and is not entitled, under sections 22(c) and 41 of the Revenue Act of 1928, to have its income determined by the use of inventories for the purpose of reducing tax liability on account of unrealized losses resulting from a decline in the market value of securities unsold at the end of the year.

1Opinion of the Court

OPINION.

Tkammell :

This is a proceeding for the redetermination of a deficiency in income tax for the year 1929 in the amount of $15,316.97. The sole issue is whether or not the petitioner is entitled to have, its income for the taxable year computed by reference to inventories of securities taken at market value at the beginning and end of the year. It is conceded that, if the taxable income is to be determined without reference to such inventories, the deficiency asserted by the respondent is correct.

The petitioner is a New York corporation, with its principal office in New York City. It was…

2Cases cited1 opinion

  1. Adirondack Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1931

3Cited by6 opinions

  1. Hall v. CommissionerUnited States Board of Tax Appeals · 1934
  2. Oil Shares, Inc. v. CommissionerUnited States Board of Tax Appeals · 1934
  3. Hamill v. CommissionerUnited States Board of Tax Appeals · 1934
  4. Northeastern Surety Co. v. CommissionerUnited States Board of Tax Appeals · 1933
  5. Oil Shares, Inc. v. CommissionerUnited States Board of Tax Appeals · 1934

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