Legal Opinion

Robertson v. Commissioner

United States Tax Court

Decided February 25, 1971No. Docket No. 5904-69PublishedCited by 29 opinions

Incident to divorce proceedings, petitioner sold his interest in a motel to his former wife. Held, on the facts, that petitioner sustained a loss, and such loss was deductible under sec. 165, I.R.C. 1954.

1Opinion of the Court

Dawson, Judge:

Respondent determined a deficiency of $1,634 in petitioner’s Federal income taxes of the year 1965. After concessions by both parties, the only issues for decision are whether petitioners sustained a loss on the disposition of his interest in motel property, and if so, whether the loss is deductible under section 165 (c), I.R.C. 1954.

FINDINGS OF FACT

Some of the facts have been stipulated and are found accordingly.

William E. Robertson and Gertie L. Robertson are husband and wife who resided in. Portland, Oreg., at the time they filed their petition in this proceeding. They filed…

2Cases cited10 opinions

  1. United States v. DavisSupreme Court of the United States · 1962
  2. Shomaker v. CommissionerUnited States Tax Court · 1962
  3. David R. Pulliam v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1964
  4. Messer v. CommissionerUnited States Tax Court · 1969
  5. Evans v. RothensiesCourt of Appeals for the Third Circuit · 1940

5 more not listed; retrieve them via the Exa API.

3Cited by29 opinions

  1. Estate of Horvath v. CommissionerUnited States Tax Court · 1973
  2. Seligman v. CommissionerUnited States Tax Court · 1985
  3. Norman and Arlene Rodman, Appellants-Cross-Appellees v. Commissioner of Internal Revenue, Appellee-Cross-AppellantCourt of Appeals for the Second Circuit · 1976
  4. Washington v. Comm'rUnited States Tax Court · 2003
  5. Illinois Power Co. v. CommissionerUnited States Tax Court · 1986

24 more not listed; retrieve them via the Exa API.

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