Legal Opinion
Ralph E. Purvis and Patricia Lee Purvis, His Wife v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided February 23, 1976No. 74--3177PublishedCited by 45 opinions
1Opinion of the Court
OPINION'
2Per curiam
Petitioner appeals a Tax Court decision [reported at 38 T.C.M. 164 (1974)] which found that since his activities during the taxable years 1963-68 did not constitute the “carrying on of a trade or business”, he was not entitled to carry over operating losses under section 172 of the Internal Revenue Code of 1954 [26 U.S.C. § 172] or to deduct lobbying expenses pursuant to § 162(e) [26 U.S.C. § 162(e)]. We affirm.
The facts of this appeal are not in dispute. Petitioner contends that they would support a finding that he was a trader of securities. Respondent argues that petitioner was…
3Cases cited4 opinions
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Cliff C. Wilson v. The United StatesUnited States Court of Claims · 1967
- de Vegvar v. CommissionerUnited States Tax Court · 1957
4Cited by45 opinions
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Green v. Comm'rUnited States Tax Court · 1984
- Robert P. Groetzinger v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1985
- Joseph A. & Dorothy D. Moller v. The United StatesCourt of Appeals for the Federal Circuit · 1983
- Groetzinger v. CommissionerUnited States Tax Court · 1984
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