Northeastern Surety Co. v. Commissioner
United States Board of Tax Appeals
Held, that during the taxable year 1929 the petitioner was not a merchant or dealer in securities within the meaning of article 105 of Regulations 74, and is not entitled, under sections 22(c) and 41 of the Revenue Act of 1928, to have its income determined by the use of inventories for the purpose of reducing tax liability on account of unrealized losses resulting from a decline in the market value of securities unsold at the end of the year.
1Opinion of the Court
NORTHEASTERN SURETY COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Northeastern Surety Co. v. Commissioner
Docket No. 62624.
United States Board of Tax Appeals
29 B.T.A. 297; 1933 BTA LEXIS 964;
November 2, 1933, Promulgated
Held, that during the taxable year 1929 the petitioner was not a merchant or dealer in securities within the meaning of article 105 of Regulations 74, and is not entitled, under sections 22(c) and 41 of the Revenue Act of 1928, to have its income determined by the use of inventories for the purpose of reducing tax liability on account of unrealized losses…
2Cases cited1 opinion
- Northeastern Surety Co. v. CommissionerUnited States Board of Tax Appeals · 1933