Lanski v. Commissioner
United States Board of Tax Appeals
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.
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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…
1Opinion of the Court
*1023OPINION.
Hill:
The first issue in this case is whether petitioner sustained a statutory net loss in 1924 which may be carried forward and deducted from gross income for 1925. The parties have stipulated that the petitioner sustained a deductible bad debt loss of $104,024.32 in 1924 on account of the worthlessness of his claim in that amount against the Fort Dearborn Furniture Co. for money loaned and advanced to the company, and that including such loss the excess of the deductions allowable to petitioner for 1924 over income amounted to $44,433.54. The parties further stipulated that if…
2Cases cited5 opinions
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Burnet v. ClarkSupreme Court of the United States · 1932
- Von Baumbach v. Sargent Land Co.Supreme Court of the United States · 1917
- Dalton v. BowersSupreme Court of the United States · 1932
- The Parker Mills v. . the Commissioners of TaxesNew York Court of Appeals · 1861
3Cited by3 opinions
- Dickinson v. Comm'rUnited States Tax Court · 1945
- Lanski v. CommissionerUnited States Board of Tax Appeals · 1936
- Weir v. CommissionerUnited States Tax Court · 1958