Ewing v. Commissioner
United States Tax Court
1. The petitioner was not engaged with her controlled corporation, The Ballet Theatre, Inc., in a joint venture for the production of ballet, and her primary motive or intent in advancing funds to the corporation during the years in question was not profit.
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1. The petitioner was not engaged with her controlled corporation, The Ballet Theatre, Inc., in a joint venture for the production of ballet, and her primary motive or intent in advancing funds to the corporation during the years in question was not profit. Held, petitioner's losses on these advances are not deductible under section 23 (e) (2), Internal Revenue Code, as losses incurred in a transaction entered into for profit. 2. The corporation's repayment of the advances received from the petitioner was subject to a contingency that did not occur, and during the years in question the…
1Opinion of the Court
Lucia Chase Ewing, Petitioner, v. Commissioner of Internal Revenue, Respondent
Ewing v. Commissioner
Docket No. 25111
United States Tax Court
20 T.C. 216; 1953 U.S. Tax Ct. LEXIS 170;
April 30, 1953, Promulgated
Decision will be entered under Rule 50.
1. The petitioner was not engaged with her controlled corporation, The Ballet Theatre, Inc., in a joint venture for the production of ballet, and her primary motive or intent in advancing funds to the corporation during the years in question was not profit. Held, petitioner's losses on these advances are not deductible under section 23 (e) (2),…
2Cases cited18 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Place v. CommissionerUnited States Tax Court · 1951
- Orvis v. . CurtissNew York Court of Appeals · 1899
- Clark v. CommissionerUnited States Tax Court · 1952
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