Legal Opinion

Thomson v. Commissioner

United States Tax Court

Decided May 19, 1983No. Docket No. 3278-80Unpublished

P held 22 percent of the stock of B, an electing small business corporation. P never paid money to B in exchange for the stock nor was B indebted to P at the end of its 1974 taxable year.

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P held 22 percent of the stock of B, an electing small business corporation. P never paid money to B in exchange for the stock nor was B indebted to P at the end of its 1974 taxable year. P claims to have made substantial expenditures on behalf of B. Held, under sec. 1374(c)(2), I.R.C. 1954, as in effect during 1974, P is not entitled to deduct his share of B's net operating loss for its 1974 taxable year, since P failed to prove that his basis in B's stock was other than zero.

1Opinion of the Court

KENNETH G. and JOAN T. THOMSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Thomson v. Commissioner

Docket No. 3278-80.

United States Tax Court

T.C. Memo 1983-279; 1983 Tax Ct. Memo LEXIS 510; 46 T.C.M. (CCH) 192; T.C.M. (RIA) 83279;

May 19, 1983.

P held 22 percent of the stock of B, an electing small business corporation. P never paid money to B in exchange for the stock nor was B indebted to P at the end of its 1974 taxable year. P claims to have made substantial expenditures on behalf of B. Held, under sec. 1374(c)(2), I.R.C. 1954, as in effect during 1974, P is not entitled to…

2Cases cited20 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Sanford v. CommissionerUnited States Tax Court · 1968
  4. William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
  5. W. Horace Williams, Sr., and Viola Bloch Williams v. United StatesCourt of Appeals for the Fifth Circuit · 1957

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