Legal Opinion

Coen v. Commissioner

United States Board of Tax Appeals

Decided February 20, 1930No. Docket No. 23173Published

Loss sustained in 1921 held not "resulting from the operation of a trade or business regularly carried on by the taxpayer," and not deductible in 1922 as a net loss under section 204, Revenue Act of 1921.

1Opinion of the Court

GARNET W. COEN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Coen v. Commissioner

Docket No. 23173.

United States Board of Tax Appeals

18 B.T.A. 1274; 1930 BTA LEXIS 2491;

February 20, 1930, Promulgated

Loss sustained in 1921 held not "resulting from the operation of a trade or business regularly carried on by the taxpayer," and not deductible in 1922 as a net loss under section 204, Revenue Act of 1921.

Ewell D. Moore, Esq., for the petitioner.

J. E. Mather, Esq., for the respondent.

STERNHAGEN

The Commissioner determined a deficiency of $1,093.85 in income tax for the calendar year…

2Cases cited1 opinion

  1. Coen v. CommissionerUnited States Board of Tax Appeals · 1930

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