Legal Opinion
United States v. Zelma T. Kyle and Betty K. Kyle
Court of Appeals for the Fourth Circuit
Decided April 2, 1957No. 7330_1PublishedCited by 4 opinions
1Opinion of the Court
WILLIAMS, District Judge.
The question here is whether an uncollectible judgment obtained in a suit on an executory contract to sell a personal residence is deductible as a nonbusiness bad debt or is a nondeductible capital loss from the sale of taxpayers’ residence.
In September 1946 Zelma T. and Betty K. Kyle, hereinafter referred to as the taxpayers, purchased a residence, located at No. 1602 Cedar Lane, Richmond, Virginia. On December 2, 1946, plaintiffs entered into a contract for the sale of the residence for $17,750, the agreement requiring a down payment of $700, and the balance to be…
2Cases cited8 opinions
- Rumsey v. CommissionerCourt of Appeals for the Second Circuit · 1936
- Gevirtz v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1941
- Stewart v. CommissionerUnited States Board of Tax Appeals · 1939
- Wenger v. CommissionerUnited States Board of Tax Appeals · 1940
- Jones v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1945
3 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Patrick Guffey and Betty Guffey v. United StatesCourt of Appeals for the Ninth Circuit · 1964
- Guffey v. United StatesDistrict Court, D. Oregon · 1963
- Taylor v. CommissionerUnited States Tax Court · 1998
- Quinn v. CommissionerUnited States Tax Court · 1983