Vreeland v. Commissioner
United States Tax Court
Petitioner's personal activities, held, on the facts, not such as to constitute a trade or business in the course of which indebtedness was incurred, so as to be deductible as a business bad debt.
1Opinion of the Court
OPINION.
Opper, Judge:
I
The question here of whether petitioner was individually engaged in the business of “promoting, managing, financing and making loans to a number of corporations” so as to make an admittedly bad debt deductible as a business debt1 is complicated by the fact that practically throughout the period covered by the evidence petitioner was working for and otherwise connected with corporations which were themselves in the business of promoting and financing other enterprises.
Our conclusion that petitioner as an individual was not engaged in the business of carrying on promotions…
2Cases cited9 opinions
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Burnet v. ClarkSupreme Court of the United States · 1932
- Campbell v. CommissionerUnited States Tax Court · 1948
- Commissioner of Internal Revenue v. SmithCourt of Appeals for the Second Circuit · 1953
- Smith v. CommissionerUnited States Tax Court · 1951
4 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Millsap v. CommissionerUnited States Tax Court · 1966
- Rollins v. CommissionerUnited States Tax Court · 1959
- Barish v. CommissionerUnited States Tax Court · 1959
- Arata v. CommissionerUnited States Tax Court · 1958
- Jarvis v. CommissionerUnited States Tax Court · 1959
15 more not listed; retrieve them via the Exa API.