Dicker v. Commissioner
United States Tax Court
Held: 1. Payments of $211,664.18 each by Dicker and Frank to a corporation in which they indirectly had a stock interest were not contributions to capital.
Read the full summary
Held: 1. Payments of $211,664.18 each by Dicker and Frank to a corporation in which they indirectly had a stock interest were not contributions to capital. The payments were indemnity payments and represented deductible losses incurred in a closed transaction entered into for profit. 2. The operation of Dicker's farm did not constitute a transaction entered into for profit and the claimed loss is not deductible. 3. None of Dicker's expenses incurred on a trip to Europe were ordinary and necessary business expenses. The trip was primarily personal in nature and no expenses were shown to be…
1Opinion of the Court
Edward T. Dicker and Nanette Dicker v. Commissioner. Jerome J. Frank and Emma Sue Frank v. Commissioner.
Dicker v. Commissioner
Docket Nos. 91032, 91033.
United States Tax Court
T.C. Memo 1963-82; 1963 Tax Ct. Memo LEXIS 263; 22 T.C.M. (CCH) 345; T.C.M. (RIA) 63082;
March 20, 1963
Held: 1. Payments of $211,664.18 each by Dicker and Frank to a corporation in which they indirectly had a stock interest were not contributions to capital. The payments were indemnity payments and represented deductible losses incurred in a closed transaction entered into for profit.
2. The operation of Dicker's farm did…
2Cases cited3 opinions
- Podems v. CommissionerUnited States Tax Court · 1955
- Tobin v. Commissioner of Internal Revenue (Two Cases)Court of Appeals for the Fifth Circuit · 1950
- D. H. McGhee and Oral Mae McGhee v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1959
3Cited by1 opinion
- Shiosaki v. CommissionerUnited States Tax Court · 1971