Batter v. Commissioner
United States Board of Tax Appeals
Losses resulting from the expiration of unexercised "puts" or options to sell stock are subject to the limitation of section 23(r) of the Revenue Act of 1932, because of the express provision of section 23(s)(B).
1Opinion of the Court
*668OPINION.
Murdock:
The petitioner allowed a number of puts to expire un-exercised during the taxable year and thereby suffered a loss of $8,249.99. The loss was incurred in transactions entered into for profit and was not compensated for by insurance or otherwise. The only question in this case is whether or not this loss was subject to the limitations of section 28 (r). If it was not, then it is deductible in'its entirety under section 28 (e). But if it is subject to the limitation of subsection (r), then no part of it is deductible and it does not benefit the petitioner in any way, since he…
2Cases cited5 opinions
- Hawaii v. MankichiSupreme Court of the United States · 1903
- Takao Ozawa v. United StatesSupreme Court of the United States · 1922
- In Re ChapmanSupreme Court of the United States · 1897
- Carbon Steel Co. v. LewellynSupreme Court of the United States · 1920
- Holliday v. BatsonSupreme Court of the United States · 1846
3Cited by1 opinion
- Batter v. CommissionerUnited States Board of Tax Appeals · 1938