Legal Opinion

Collins v. Commissioner

United States Tax Court

Decided June 27, 1960No. Docket Nos. 69165, 69166PublishedCited by 5 opinions

Petitioner's ownership and operation of the Boston Yanks and the New York Bulldogs, professional football teams, under different franchises and in different but successive years, held, to constitute separate business within the meaning of section 130, I.R.C. 1939, and losses of the Yanks cannot be tacked on to losses of the Bulldogs and its successor to permit disallowance of losses in excess of $ 50,000 attributable to a trade or business carried on for 5 consecutive years…

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Petitioner's ownership and operation of the Boston Yanks and the New York Bulldogs, professional football teams, under different franchises and in different but successive years, held, to constitute separate business within the meaning of section 130, I.R.C. 1939, and losses of the Yanks cannot be tacked on to losses of the Bulldogs and its successor to permit disallowance of losses in excess of $ 50,000 attributable to a trade or business carried on for 5 consecutive years under section 130.

1Opinion of the Court

Deennbn, Judge:

Respondent determined deficiencies in income tax of petitioner as follows:

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The only issue is whether respondent properly disallowed losses in excess of $50,000 incurred by petitioner in the operation of professional football teams during each of the years 1947 to 1951, inclusive, under section 130,1.R.C. 1939.1

FINDINGS op pact.

The stipulated facts are so found.

Joseph M. Collins, also known as Ted Collins and hereafter referred to as petitioner, is an individual who resided in New York, New York, during the taxable years involved. Petitioner filed his individual…

2Cases cited1 opinion

  1. Davis v. CommissionerUnited States Tax Court · 1958

3Cited by5 opinions

  1. Californians Helping to Alleviate Med. Problems, Inc. v. Comm'rUnited States Tax Court · 2007
  2. Californians Helping to Alleviate Med. Problems, Inc. v. Comm'rUnited States Tax Court · 2007
  3. Californians Helping to Alleviate Medical Problems, Inc. v. CommissionerUnited States Tax Court · 2007
  4. Collins v. CommissionerUnited States Tax Court · 1960
  5. Roselle v. CommissionerUnited States Tax Court · 1981

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