Campbell v. Commissioner
United States Tax Court
In 1971, Ps purchased two certificates evidencing securities in a corporation, which were issued in the names of their sons. The certificates were never delivered to the sons, and Ps reported all income from such securities on their joint returns. In 1975, the securities became worthless, and Ps claimed a bad debt deduction. Held, the securities represented stock, and Ps were the owners thereof.
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In 1971, Ps purchased two certificates evidencing securities in a corporation, which were issued in the names of their sons. The certificates were never delivered to the sons, and Ps reported all income from such securities on their joint returns. In 1975, the securities became worthless, and Ps claimed a bad debt deduction. Held, the securities represented stock, and Ps were the owners thereof. Ps are entitled to a deduction for worthless securities; they are not entitled to a deduction for a bad debt or for a theft loss.
1Opinion of the Court
WILLIAM H. CAMPBELL, JR. and PEGGY L. CAMPBELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Campbell v. Commissioner
Docket No. 9804-77.
United States Tax Court
T.C. Memo 1979-411; 1979 Tax Ct. Memo LEXIS 116; 39 T.C.M. (CCH) 287; T.C.M. (RIA) 79411;
September 27, 1979, Filed
In 1971, Ps purchased two certificates evidencing securities in a corporation, which were issued in the names of their sons. The certificates were never delivered to the sons, and Ps reported all income from such securities on their joint returns. In 1975, the securities became worthless, and Ps claimed a bad…
2Cases cited18 opinions
- Edwards v. BrombergCourt of Appeals for the Fifth Circuit · 1956
- Monteleone v. CommissionerUnited States Tax Court · 1960
- Towers v. CommissionerUnited States Tax Court · 1955
- Weil v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1936
- Allen v. CommissionerUnited States Tax Court · 1951
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