Mohr v. Commissioner
United States Tax Court
1. Held, petitioner, Eugene A. Mohr, was not engaged in a business of buying and selling automobile dealerships; interest, bad debts, and worthless stock losses related to dealerships promoted by petitioner were nonbusiness deductions and, under section 172(d) (4), I.R.C. 1954, could not give rise to net operating loss carrybacks to the years in question. 2. Held, further, petitioners have failed to show error in respondent's determination that certain disbursements by a…
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1. Held, petitioner, Eugene A. Mohr, was not engaged in a business of buying and selling automobile dealerships; interest, bad debts, and worthless stock losses related to dealerships promoted by petitioner were nonbusiness deductions and, under section 172(d) (4), I.R.C. 1954, could not give rise to net operating loss carrybacks to the years in question. 2. Held, further, petitioners have failed to show error in respondent's determination that certain disbursements by a corporation controlled by petitioner Eugene A. Mohr, designated as travel and entertainment expense and yacht expense, were…
1Opinion of the Court
IIoxt, Judge:
These consolidated proceedings involve deficiencies in income tax determined by respondent for the years 1957 and 1958 as follows:
Docket No. Petitioner Taxable year Deficiency 96235. 95236. 95237. Eugene A. Mohr. Eugene A. Mohr. Joyce Mohr_ 1957 1958 1957 $4,322.96 5,401.20 4,322.96
Joyce Mohr is a petitioner herein solely by reason of her having joined with Eugene A. Mohr in filing a joint return for 1957. Because the deficiencies involved in these cases relate only to the income of Eugene A. Mohr, references hereinafter to petitioner in the singular shall be to Eugene A. Mohr.
The…
2Cases cited9 opinions
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Burnet v. ClarkSupreme Court of the United States · 1932
- Dalton v. BowersSupreme Court of the United States · 1932
- Vincent C. Giblin v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1955
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3Cited by16 opinions
- Millsap v. CommissionerUnited States Tax Court · 1966
- Ma-Tran Corp. v. CommissionerUnited States Tax Court · 1978
- Weigman v. CommissionerUnited States Tax Court · 1967
- C. F. Mueller Co. v. CommissionerUnited States Tax Court · 1970
- Bowman v. CommissionerUnited States Tax Court · 1969
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