Arata v. Commissioner
United States Tax Court
Held: (1) Petitioner was not in the business of financing corporations and a claimed loss resulting from a transaction whereby he exchanged 765 shares of stock in Snyder & Black having a fair market value of $ 50 per share for 765 shares of stock in Salers having no fair market value is not deductible as a loss incurred in trade or business within the meaning of section 23 (e) (1), I. R. C. 1939, or as a loss incurred in a transaction entered into for profit within the…
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Held: (1) Petitioner was not in the business of financing corporations and a claimed loss resulting from a transaction whereby he exchanged 765 shares of stock in Snyder & Black having a fair market value of $ 50 per share for 765 shares of stock in Salers having no fair market value is not deductible as a loss incurred in trade or business within the meaning of section 23 (e) (1), I. R. C. 1939, or as a loss incurred in a transaction entered into for profit within the meaning of section 23 (e) (2). (2) Respondent's determination of additions to tax under the provisions of sections 294 (d)…
1Opinion of the Court
George F. Arata and Carolyn M. Arata, Petitioners, v. Commissioner of Internal Revenue, Respondent
Arata v. Commissioner
Docket No. 67293
United States Tax Court
31 T.C. 346; 1958 U.S. Tax Ct. LEXIS 38;
November 12, 1958, Filed
Decision will be entered for the respondent.
Held: (1) Petitioner was not in the business of financing corporations and a claimed loss resulting from a transaction whereby he exchanged 765 shares of stock in Snyder & Black having a fair market value of $ 50 per share for 765 shares of stock in Salers having no fair market value is not deductible as a loss incurred in trade or…
2Cases cited21 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Burnet v. ClarkSupreme Court of the United States · 1932
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