Hedrick v. Commissioner
United States Board of Tax Appeals
In 1923 the petitioner was president and general manager of a construction company of which he owned 80 per cent of the capital stock. The corporation became insolvent and was dissolved in 1924, the petitioner losing his investment therein. held that the loss sustained was not a loss "resulting from the operation of any trade or business regularly carried on by the taxpayer" within the provisions of section 204(a) of the Revenue Act of 1921.
1Opinion of the Court
*259OPINION.
Smith :
The only question presented by this proceeding is whether the petitioner is entitled to deduct from gross income of the year 1925 a loss of $84,606.11 sustained in 1924 as a result of certain shares of stock owned by him in the W. C. Hedrick Construction Co. becoming worthless in that year. The petitioner claims that the loss on this stock was a loss “ resulting from the operation of ” a “ trade or business regularly carried on by the taxpayer ” within the purview of section 204(a) of the Revenue Act of 1921, and that as a result thereof the amount may be deducted from the…
2Cited by2 opinions
- Cappon v. CommissionerUnited States Board of Tax Appeals · 1933
- Hedrick v. CommissionerUnited States Board of Tax Appeals · 1930