Lanski v. Commissioner

1. In 1924 petitioner deducted as a bad debt his claim against a corporation organized and financed by petitioner and his brothers. Including such deduction, the deductions allowable to petitioner for 1924 exceeded his gross income. Held, petitioner was not regularly engaged in the business of promoting, managing, and financing corporations, and the excess of his deductions over income for 1924 is not allowable as a net loss deductible from income for 1925, under the provisions of section 206 of the Revenue Act of 1926. 2. On the facts, held that petitioner received no taxable income in 1926…