Holeproof Hosiery Co. v. Commissioner
United States Board of Tax Appeals
1. Disallowance of a deduction for an alleged loss approved. 2. An amount paid in connection with an increase in the capital stock of the petitioner to the State of Wisconsin in accordance with the law of that State held deductible as a tax under section 234(a)(3) of the Revenue Act of 1921. 3. Attorneys' fees paid in the same connection were not ordinary and necessary expenses within the meaning of section 234(a)(1) of the Revenue Act of 1921. 4. An amount paid as rental on…
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1. Disallowance of a deduction for an alleged loss approved. 2. An amount paid in connection with an increase in the capital stock of the petitioner to the State of Wisconsin in accordance with the law of that State held deductible as a tax under section 234(a)(3) of the Revenue Act of 1921. 3. Attorneys' fees paid in the same connection were not ordinary and necessary expenses within the meaning of section 234(a)(1) of the Revenue Act of 1921. 4. An amount paid as rental on machines in which the petitioner with each payment acquired an equity was not deductible under section 234(a)(1) of the…
1Opinion of the Court
*552OPINION.
Murdock :
The petitioner contends that it sustained a loss of $1,000 during the taxable year in connection with its stock in the Milwaukee, Chicago & Michigan City Line. Satisfactory evidence that this stock was worthless at the end of 1921, has not been offered. An *553alleged loss of this kind must be supported by facts which show that it was in fact sustained and is not established by the mere showing that the petitioner heard a rumor that the company was in financial straits.
The petitioner claims the right to deduct the amount of $1,760 under section 234 (a) (3) of the Revenue Act of…
2Cases cited19 opinions
- Gould v. GouldSupreme Court of the United States · 1917
- Norwood v. BakerSupreme Court of the United States · 1898
- Gundling v. ChicagoSupreme Court of the United States · 1900
- Ward v. MarylandSupreme Court of the United States · 1871
- United States v. WoodwardSupreme Court of the United States · 1921
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3Cited by42 opinions
- Estate of Thomas v. CommissionerUnited States Tax Court · 1985
- General Bancshares Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
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- New England Tank Industries, Inc. v. CommissionerUnited States Tax Court · 1968
- National Starch & Chemical Corp. v. CommissionerUnited States Tax Court · 1989
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