Legal Opinion

Levy v. Commissioner

United States Board of Tax Appeals

Decided February 25, 1942No. Docket No. 105086Published

Petitioner, the owner of all the outstanding stock of corporation, sold that stock at a loss in the taxable year. The corporation had become indebted to petitioner for advances made over a period of years and, in the taxable year, petitioner sold his claim against the corporation to the purchaser of the stock of the corporation for an amount less than the face value of the debt.

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Petitioner, the owner of all the outstanding stock of corporation, sold that stock at a loss in the taxable year. The corporation had become indebted to petitioner for advances made over a period of years and, in the taxable year, petitioner sold his claim against the corporation to the purchaser of the stock of the corporation for an amount less than the face value of the debt. At the end of the taxable year and after the stock and debt had been sold, petitioner charged off on his books the difference between the amount of the debt and the amount which he received on its sale. Held, that…

1Opinion of the Court

MAURICE LEVY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Levy v. Commissioner

Docket No. 105086.

United States Board of Tax Appeals

46 B.T.A. 423; 1942 BTA LEXIS 864;

February 25, 1942, Promulgated

Petitioner, the owner of all the outstanding stock of corporation, sold that stock at a loss in the taxable year. The corporation had become indebted to petitioner for advances made over a period of years and, in the taxable year, petitioner sold his claim against the corporation to the purchaser of the stock of the corporation for an amount less than the face value of the debt. At the…

2Cases cited1 opinion

  1. Levy v. CommissionerUnited States Board of Tax Appeals · 1942

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