Legal Opinion
S. D. Ferguson v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided March 6, 1958No. 7558PublishedCited by 29 opinions
1Opinion of the Court
HAYNSWORTH, Circuit Judge.
This is an appeal from a decision of the Tax Court, 28 T.C. 432, in which the Tax Court affirmed a deficiency assessment based upon the disallowance of a deduction of a claimed business bad debt. The question arises under Section 23 of the Internal Revenue Code of 1939, 26 U.S. C.A. § 23, and requires a review of the Tax Court’s finding that the taxpayer was not engaged, in the relevant years, in the business of promoting and financing corporate ventures and of its conclusion, based upon the finding, that Section 23 (k) (1) and (4) prohibited a deduction of the loss.
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2Cases cited11 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Burnet v. ClarkSupreme Court of the United States · 1932
- Commissioner of Internal Revenue v. SmithCourt of Appeals for the Second Circuit · 1953
- Langdon L. Skarda, Carolyn A. Skarda, Lynell G. Skarda, Kathryn B. Skarda, Cash T. Skarda and Annabel S. Skarda v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1957
- Samuel Towers v. Commissioner of Internal Revenue, and Three Related CasesCourt of Appeals for the Second Circuit · 1957
6 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- H. Beale Rollins and Mary E. Rollins v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- Rollins v. CommissionerUnited States Tax Court · 1959
- Zivnuska v. CommissionerUnited States Tax Court · 1959
- Pachella v. CommissionerUnited States Tax Court · 1961
- Shea v. CommissionerUnited States Tax Court · 1961
24 more not listed; retrieve them via the Exa API.