Crow v. Commissioner
United States Tax Court
Petitioners (H & W) sustained capital losses in 1970 upon sales of stock in Bankers National and Lomas & Nettleton. They claimed such losses as "business capital losses" within sec. 1.172-3(a)(2), Income Tax Regs., in computing their net operating loss under sec. 172, I.R.C. 1954. Held, the Bankers National loss was a "nonbusiness" capital loss since it has been found herein not to be directly related to or "attributable to" H's real estate business, and was therefore…
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Petitioners (H & W) sustained capital losses in 1970 upon sales of stock in Bankers National and Lomas & Nettleton. They claimed such losses as "business capital losses" within sec. 1.172-3(a)(2), Income Tax Regs., in computing their net operating loss under sec. 172, I.R.C. 1954. Held, the Bankers National loss was a "nonbusiness" capital loss since it has been found herein not to be directly related to or "attributable to" H's real estate business, and was therefore subject to the limitations of sec. 172(d)(2) and ( 4), I.R.C. 1954, and the foregoing regulations. Held, further, the Lomas &…
1Opinion of the Court
Trammell Crow and Margaret D. Crow, Petitioners v. Commissioner of Internal Revenue, Respondent
Crow v. Commissioner
Docket No. 3239-76
United States Tax Court
79 T.C. 541; 1982 U.S. Tax Ct. LEXIS 35; 79 T.C. No. 35;
September 27, 1982, Filed
Decision will be entered under Rule 155.
Petitioners (H & W) sustained capital losses in 1970 upon sales of stock in Bankers National and Lomas & Nettleton. They claimed such losses as "business capital losses" within sec. 1.172-3(a)(2), Income Tax Regs., in computing their net operating loss under sec. 172, I.R.C. 1954. Held, the Bankers National loss was a…
2Cases cited16 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Dalton v. BowersSupreme Court of the United States · 1932
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- W. W. Windle Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1977
- W. W. Windle Co. v. CommissionerUnited States Tax Court · 1976
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