1955 Production Exposition, Inc. v. Commissioner
United States Tax Court
Corporate petitioner, engaged in the promotion and operation of trade expositions, made an incidental short sale of 2,500 shares of stock in a corporation which had already adopted a plan of liquidation and declared a $ 20 liquidating dividend.
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Corporate petitioner, engaged in the promotion and operation of trade expositions, made an incidental short sale of 2,500 shares of stock in a corporation which had already adopted a plan of liquidation and declared a $ 20 liquidating dividend. Held, corporate petitioner was not a dealer or trader in securities and therefore its payment of $ 50,000 on account of the liquidating dividend on the short sale transaction was not an ordinary and necessary business expense under section 162 of the 1954 Internal Revenue Code.
1Opinion of the Court
1955 Production Exposition, Inc., in Dissolution, Saul Poliak, J. Stanley Halperin, and Elliott E. Ruskin, Trustees, Petitioner, v. Commissioner of Internal Revenue, Respondent; Saul Poliak, Transferee of 1955 Production Exposition, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
1955 Production Exposition, Inc. v. Commissioner
Docket Nos. 88556, 88557
United States Tax Court
41 T.C. 85; 1963 U.S. Tax Ct. LEXIS 33;
October 22, 1963, Filed
Decisions will be entered for the respondent.
Corporate petitioner, engaged in the promotion and operation of trade expositions, made an…
2Cases cited13 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Wilson v. CommissionerUnited States Tax Court · 1948
- Wilson Bros. & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1948
- Wiesler v. CommissionerUnited States Tax Court · 1946
- Commissioner v. WieslerCourt of Appeals for the Sixth Circuit · 1947
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