Legal Opinion
Commissioner v. Coggan
Court of Appeals for the First Circuit
Decided May 2, 1941No. Nos. 3576, 3577PublishedCited by 2 opinions
1Opinion of the Court
MAGRUDER, Circuit Judge.
These are cross-petitions for review of a decision of the Board of Tax Appeals redetermining a deficiency in the taxpayer’s income tax for the year 1935. The question presented by the Commissioner’s petition is whether two losses, conceded to have been sustained by the taxpayer in 1935, are ordinary losses entitled to full deduction, or are losses “from sales or exchanges of capital assets” entitled to be deducted only to the limited extent provided in § 117 of the Revenue Act of 1934, 48 Stat. 680, 26 U.S.C.A. Int.Rev.Acts, page 707. If the losses are found to be of…
2Cases cited8 opinions
- Helvering v. HammelSupreme Court of the United States · 1941
- Electro-Chemical Engraving Co. v. CommissionerSupreme Court of the United States · 1941
- Commissioner of Internal Revenue v. FreihoferCourt of Appeals for the Third Circuit · 1939
- Helvering v. Nebraska Bridge Supply & Lumber Co.Supreme Court of the United States · 1941
- Commissioner of Internal Revenue v. PetermanCourt of Appeals for the Ninth Circuit · 1941
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3Cited by2 opinions
- Hawaiian Gas Products v. Commissioner of Int. Rev.Court of Appeals for the Ninth Circuit · 1942
- O'Madigan v. CommissionerUnited States Tax Court · 1960