Legal Opinion
Loewi & Co. v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided May 18, 1956No. 11456PublishedCited by 20 opinions
1Opinion of the Court
SWAIM, Circuit Judge.
The question presented is whether or not the petitioner, Loewi & Co., incurred during its fiscal year ending November 30, 1946, either a “bad debt” deductible from income under Section 23(k) (1) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 23(k) (1), or a “loss” deductible under Section 23(f), 26 U.S.C.A. § 23(f).
The petitioner is a stockbroker. During 1946 it purchased for a customer certain “when, as and if issued” contracts to purchase shares of stock of certain railway corporations. These contracts constituted a promise to buy a certain number of shares of such…
2Cases cited11 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Commissioner of Internal Revenue v. McKay Products Corporation. McKay Products Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1949
- Mayer Tank Mfg. Co. v. CommissionerCourt of Appeals for the Second Circuit · 1942
- Loewi & Co. v. CommissionerUnited States Tax Court · 1954
6 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Richard R. Riss, Sr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1973
- Roth Steel Tube Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1980
- Zeeman v. United StatesDistrict Court, S.D. New York · 1967
- Melvin J. Cole and Harriet L. Cole v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1989
- Jordan v. CommissionerUnited States Tax Court · 1973
15 more not listed; retrieve them via the Exa API.