Legal Opinion

Parker v. Commissioner

United States Board of Tax Appeals

Decided November 21, 1934No. Docket No. 58604Published

1. Decedent made loans or advances for several years prior to 1927 to a corporation in which he owned a controlling interest, and in that year was allowed a deduction for a loss on that account which was unabsorbed by income of that year.

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1. Decedent made loans or advances for several years prior to 1927 to a corporation in which he owned a controlling interest, and in that year was allowed a deduction for a loss on that account which was unabsorbed by income of that year. Held, the unabsorbed loss is not a net loss that may be carried forward to the succeeding year as it was not sustained in a trade or business regularly carried on by decedent. 2. The partnership of George D. Parker Co. was composed of five persons, decedent having a one-fourth interest only, as determined in 30 B.T.A. 1231. Held, respondent erred in…

1Opinion of the Court

CLARA B. PARKER, EXECUTRIX OF THE ESTATE OF GEORGE D. PARKER, DECEASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Parker v. Commissioner

Docket No. 58604.

United States Board of Tax Appeals

31 B.T.A. 644; 1934 BTA LEXIS 1052;

November 21, 1934, Promulgated

1. Decedent made loans or advances for several years prior to 1927 to a corporation in which he owned a controlling interest, and in that year was allowed a deduction for a loss on that account which was unabsorbed by income of that year. Held, the unabsorbed loss is not a net loss that may be carried forward to the succeeding…

2Cases cited11 opinions

  1. Burnet v. ClarkSupreme Court of the United States · 1932
  2. Pereira v. PereiraCalifornia Supreme Court · 1909
  3. United States v. MalcolmSupreme Court of the United States · 1931
  4. Estate of GoldCalifornia Supreme Court · 1915
  5. Malta Temple Ass'n v. CommissionerUnited States Board of Tax Appeals · 1929

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