Legal Opinion

Ford v. Commissioner

United States Tax Court

Decided October 22, 1958No. Docket No. 64910Published

In order for a loss incurred by a taxpayer to be exempt from application of section 122 (d) (5), I. R. C. 1939, limiting net loss carryback of loss not attributable to operation of trade or business regularly carried on by the taxpayer to the amount of gross income not derived from such trade or business, such loss must be incurred in the normal day-to-day operation of the taxpayer's regular trade or business.

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In order for a loss incurred by a taxpayer to be exempt from application of section 122 (d) (5), I. R. C. 1939, limiting net loss carryback of loss not attributable to operation of trade or business regularly carried on by the taxpayer to the amount of gross income not derived from such trade or business, such loss must be incurred in the normal day-to-day operation of the taxpayer's regular trade or business. Held, the Commissioner is sustained in his determination that the taxpayer in the instant case did not have a net operating loss in 1953 within the meaning of section 122, 1939 Code,…

1Opinion of the Court

Roy E. Ford and Bonnie J. Ford, Petitioners, v. Commissioner of Internal Revenue, Respondent

Ford v. Commissioner

Docket No. 64910

United States Tax Court

31 T.C. 119; 1958 U.S. Tax Ct. LEXIS 58;

October 22, 1958, Filed

Decision will be entered for the respondent.

In order for a loss incurred by a taxpayer to be exempt from application of section 122 (d) (5), I. R. C. 1939, limiting net loss carryback of loss not attributable to operation of trade or business regularly carried on by the taxpayer to the amount of gross income not derived from such trade or business, such loss must be incurred in the…

2Cases cited10 opinions

  1. Halle v. CommissionerUnited States Tax Court · 1946
  2. Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
  3. Sic v. CommissionerUnited States Tax Court · 1948
  4. Sic v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1949
  5. M. C. Parrish & Co. v. CommissionerUnited States Tax Court · 1944

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