Sauvigne v. Commissioner
United States Tax Court
The petitioner held stock in an electing small business corporation, which sustained an operating loss in the year 1965. On his own return for that year, the petitioner claimed a deduction for what he considered to be his proportionate share of the corporate loss. Held, he is not entitled to such a deduction because of his complete failure to prove his basis in the stock.
1Opinion of the Court
Donald J. and Joan R. Sauvigne v. Commissioner.
Sauvigne v. Commissioner
Docket No. 3293-69SC.
United States Tax Court
T.C. Memo 1971-30; 1971 Tax Ct. Memo LEXIS 301; 30 T.C.M. (CCH) 123; T.C.M. (RIA) 71030;
February 11, 1971, Filed
The petitioner held stock in an electing small business corporation, which sustained an operating loss in the year 1965. On his own return for that year, the petitioner claimed a deduction for what he considered to be his proportionate share of the corporate loss. Held, he is not entitled to such a deduction because of his complete failure to prove his basis in the…
2Cases cited14 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Robertson v. United StatesSupreme Court of the United States · 1952
- Haber v. CommissionerUnited States Tax Court · 1969
9 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Thomson v. CommissionerUnited States Tax Court · 1983