Legal Opinion

Pollak v. Commissioner of Internal Revenue

Court of Appeals for the Third Circuit

Decided January 6, 1954No. 11166PublishedCited by 22 opinions

1Opinion of the Court

MARIS, Circuit Judge.

This is a petition by the taxpayers to review a decision of the Tax Court as to their income tax liability for the taxable year 1949. The sole question involved is whether the court erred in holding that a loss sustained by the taxpayers in that year was a non-business bad debt deductible as a short-term capital loss only to the limited extent permitted by Section 23 (k) (4) of the Internal Revenue Code, 26 U.S.C., rather than an ordinary loss resulting from a transaction entered into for profit and deductible in full under Section 23(e) (2) of the Code, as the taxpayers…

2Cases cited6 opinions

  1. Eckert v. BurnetSupreme Court of the United States · 1931
  2. Helvering v. PriceSupreme Court of the United States · 1940
  3. Shiman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1932
  4. Fox v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1951
  5. Pollak v. CommissionerUnited States Tax Court · 1953

1 more not listed; retrieve them via the Exa API.

3Cited by22 opinions

  1. Putnam v. CommissionerSupreme Court of the United States · 1956
  2. Lawrence v. CommissionerUnited States Tax Court · 1957
  3. Stamos v. CommissionerUnited States Tax Court · 1954
  4. Frank Nelson, Jr. And Lee Etta Nelson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1960
  5. Max Putnam and Elizabeth Putnam v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1955

17 more not listed; retrieve them via the Exa API.

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