Legal Opinion
Exposition Souvenir Corp. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided July 8, 1947No. 245, Docket 20230PublishedCited by 20 opinions
1Opinion of the Court
SWAN, Circuit Judge.
The question presented by this appeal is whether a loss sustained by the taxpayer on the sale of New York World’s Fair debentures, which it purchased as a condition precedent to obtaining souvenir and postcard concessions at the Fair, should be considered a long-term capital loss or a business expense in computing the taxpayer’s excess profits tax for the fiscal year ending May 31, 1941.
The facts as found by the Tax Court are as follows: The taxpayer, a New York corporation, was organized in 1938 for the purpose of acquiring and operating concessions for the sale of…
2Cases cited4 opinions
- Fuld v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1943
- Van Suetendael v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Second Circuit · 1945
- Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1932
- Reynolds v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1946
3Cited by20 opinions
- Commissioner of Internal Revenue v. The Bagley & Sewall Co.Court of Appeals for the Second Circuit · 1955
- Western Wine & Liquor Co. v. CommissionerUnited States Tax Court · 1952
- Bagley & Sewall Co. v. CommissionerUnited States Tax Court · 1953
- Smith & Welton, Inc. v. United StatesDistrict Court, E.D. Virginia · 1958
- Missisquoi Corp. v. CommissionerUnited States Tax Court · 1962
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