Hale v. Commissioner
United States Board of Tax Appeals
1. LOSS - TRANSACTION ENTERED INTO FOR PROFIT. - The purchase of stock marks the beginning of a transaction entered into for profit and gain or loss is to be determined with reference to that event.
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1. LOSS - TRANSACTION ENTERED INTO FOR PROFIT. - The purchase of stock marks the beginning of a transaction entered into for profit and gain or loss is to be determined with reference to that event. Upon sale of the stock at cost with a guaranty against loss by the purchaser, the amount which is paid under the guaranty within the year of the original purchase is a deductible loss arising out of a transaction entered into for profit. 2. CAPITAL LOSS - WORTHLESS NOTES. - The loss sustained because of inability to collect on notes is not a capital loss, the losses allowable as capital losses…
1Opinion of the Court
OPINION.
Arundell:
These proceedings, consolidated for trial, involve deficiencies in income tax for 1929. In the case of It. W. Hale, the deficiency determined by the respondent is in the amount of $1,166.72, and in the case of W. T. Hale, Jr., $4,802.15.
The petitioners allege error in the respondent’s refusal to allow a deduction for a claimed loss in connection with the sale of stock and in his refusal to allow as a capital loss the amount of loss sustained in connection with the sale of land. A stipulation of facts and certain exhibits were offered at the trial as the entire evidence of the…
2Cited by16 opinions
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- United States v. H. F. Keeler and Alice H. Keeler, His WifeCourt of Appeals for the Ninth Circuit · 1962
- E. I. Du Pont de Nemours & Co. v. United StatesUnited States Court of Claims · 1973
- Nahey v. CommissionerUnited States Tax Court · 1998
- Commissioner v. BacherCourt of Appeals for the Sixth Circuit · 1939
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