Bullock v. Commissioner
United States Board of Tax Appeals
1. Where petitioner in 1913 acquired stock in a corporation which he in 1923 exchanged for stock in another corporation on which transaction neither a gain nor loss was recognizable under the statute, and in 1924 sold at a loss part of the stock acquired in 1923, the loss is not a "capital net loss" under the provisions of section 208 of the Revenue Act of 1924, the new stock not having been held for more than two years. 2. Loss from the sale of real estate originally…
Read the full summary
1. Where petitioner in 1913 acquired stock in a corporation which he in 1923 exchanged for stock in another corporation on which transaction neither a gain nor loss was recognizable under the statute, and in 1924 sold at a loss part of the stock acquired in 1923, the loss is not a "capital net loss" under the provisions of section 208 of the Revenue Act of 1924, the new stock not having been held for more than two years. 2. Loss from the sale of real estate originally acquired as a residence and later converted into business property determined.
1Opinion of the Court
*713OPINION.
Love :
The two issues remaining in this proceeding are (1) whether the loss of $59,930 referred to in the findings was a “ capital net loss ” within the meaning of that term as used in section 208 of the Eevenue Act of 1924, and (2) whether either petitioner or his wife sustained a loss on the sale in 1924, of the real estate located at 111 East 57th Street, New York City, and if so, the amount thereof.
In connection with the first issue, petitioner contends that he did not hold the stock in the new company which he sold in 1924 for more than two years and that, therefore, the loss…
2Cases cited5 opinions
- United States v. LudeySupreme Court of the United States · 1927
- United States v. FlannerySupreme Court of the United States · 1925
- Marr v. United StatesSupreme Court of the United States · 1925
- Heiner v. TindleSupreme Court of the United States · 1928
- McCaughn v. LudingtonSupreme Court of the United States · 1925
3Cited by6 opinions
- Belden v. CommissionerUnited States Board of Tax Appeals · 1934
- Wood v. CommissionerUnited States Board of Tax Appeals · 1934
- Biesik v. CommissionerUnited States Tax Court · 1963
- Bullock v. CommissionerUnited States Board of Tax Appeals · 1931
- Hix v. CommissionerUnited States Tax Court · 1979
1 more not listed; retrieve them via the Exa API.