Brochon v. Commissioner
United States Board of Tax Appeals
1. Where certain stock purchased on margin by the petitioner was sold in 1929 through his broker, and at the same time a like amount of the same stock was, upon order of petitioner, purchased on margin through the same broker in the name of petitioner's wife; and, the wife having no account with such broker and no funds of her own, the petitioner was required to guarantee her account; and, upon the sale of such stock in 1930, the resultant loss was charged to petitioner's…
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1. Where certain stock purchased on margin by the petitioner was sold in 1929 through his broker, and at the same time a like amount of the same stock was, upon order of petitioner, purchased on margin through the same broker in the name of petitioner's wife; and, the wife having no account with such broker and no funds of her own, the petitioner was required to guarantee her account; and, upon the sale of such stock in 1930, the resultant loss was charged to petitioner's account, held, under all the circumstances, such transaction did not constitute a bona fide sale in 1929 resulting in a…
1Opinion of the Court
W. E. BROCHON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Brochon v. Commissioner
Docket No. 61455.
United States Board of Tax Appeals
30 B.T.A. 404; 1934 BTA LEXIS 1332;
April 17, 1934, Promulgated
1. Where certain stock purchased on margin by the petitioner was sold in 1929 through his broker, and at the same time a like amount of the same stock was, upon order of petitioner, purchased on margin through the same broker in the name of petitioner's wife; and, the wife having no account with such broker and no funds of her own, the petitioner was required to guarantee her account;…
2Cases cited7 opinions
- Gummey v. CommissionerUnited States Board of Tax Appeals · 1932
- Uihlein v. CommissionerUnited States Board of Tax Appeals · 1934
- Blumenthal v. CommissionerUnited States Board of Tax Appeals · 1934
- Esperson v. CommissionerUnited States Board of Tax Appeals · 1928
- Brochon v. CommissionerUnited States Board of Tax Appeals · 1934
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