Speyer v. Commissioner
United States Board of Tax Appeals
1. On April 6, 1917, large amounts were due the petitioner, a citizen of the United States, by banks and bankers in Germany. In 1925, 1926, and 1927 the Mixed Claims Commission entered awards, aggregating the principal amount of about $1,000,000, in favor of the petitioner respecting the amounts owing to him. In 1928 the Secretary of the Treasury, pursuant to provisions of the Settlement of War Claims Act of 1928, paid a portion of the amount of the awards.
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1. On April 6, 1917, large amounts were due the petitioner, a citizen of the United States, by banks and bankers in Germany. In 1925, 1926, and 1927 the Mixed Claims Commission entered awards, aggregating the principal amount of about $1,000,000, in favor of the petitioner respecting the amounts owing to him. In 1928 the Secretary of the Treasury, pursuant to provisions of the Settlement of War Claims Act of 1928, paid a portion of the amount of the awards. Held, following Burnet v. Logan,283 U.S. 404, that the petitioner is entitled to recover his cost or other basis for each award before…
1Opinion of the Court
OPINION.
Seawell:
This proceeding was instituted to redetermine a deficiency of $48,643.92 in income tax for 1928. The primar}? facts are set forth in a voluminous stipulation of facts. Only sq much of the agreed facts will be stated as is necessary for a clear understanding of the several issues raised by the pleadings, which are whether the respondent erred:(1) In increasing gross income by $181,535.45 on account of payments received on awards of the Mixed Claims Commission;(2) In refusing to. allow as a deduction losses sustained on the accounts which formed the basis of the awards;(3) In…
2Cases cited8 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Kornhauser v. United StatesSupreme Court of the United States · 1928
- Burnet v. LoganSupreme Court of the United States · 1931
- Tyler v. United StatesSupreme Court of the United States · 1930
3 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Ullman v. CommissionerUnited States Tax Court · 1960
- Ullmann v. CommissionerUnited States Board of Tax Appeals · 1934
- Benichou v. CommissionerUnited States Tax Court · 1970
- Nadler v. CommissionerUnited States Tax Court · 1988
- Speyer v. CommissionerUnited States Board of Tax Appeals · 1934
2 more not listed; retrieve them via the Exa API.