Lagreide v. Commissioner
United States Tax Court
In 1949, petitioners, husband and wife, filed a joint return disclosing a net operating loss, one-half of which was carried back by each to 1947 in which year they filed separate returns on a community property basis. In 1949, the husband sustained a loss in the operation of the XL Company, a sole proprietorship. In the same year, the wife received rents from a single piece of property and also salary income from teaching school.
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In 1949, petitioners, husband and wife, filed a joint return disclosing a net operating loss, one-half of which was carried back by each to 1947 in which year they filed separate returns on a community property basis. In 1949, the husband sustained a loss in the operation of the XL Company, a sole proprietorship. In the same year, the wife received rents from a single piece of property and also salary income from teaching school. Held, that the income from rents and salary received by the wife constituted income from "the operation of a trade or business regularly carried on" which, for…
1Opinion of the Court
OPINION.
FisheR, Judge:
All of the facts have been stipulated and are herein incorporated by reference.
Petitioners are husband and wife who during the taxable years 1947 and 1949 resided in Kent, Washington. They filed separate income tax returns on a community property basis for the year 1947 and a joint return for the year 1949. All returns were filed with the collector of internal revenue for the district of Washington at Tacoma.
Petitioner Anders I. Lagreide owned and operated a sole proprietorship, doing business under the name of XL Products Company (hereinafter called the company) in…
2Cases cited10 opinions
- Hazard v. CommissionerUnited States Tax Court · 1946
- Hill v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1950
- Fackler v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
- Industrial Commission v. HammondSupreme Court of Colorado · 1925
- Campbell v. CommissionerUnited States Tax Court · 1945
5 more not listed; retrieve them via the Exa API.
3Cited by73 opinions
- Curphey v. CommissionerUnited States Tax Court · 1980
- Mendes v. Comm'rUnited States Tax Court · 2003
- Johnson v. CommissionerUnited States Tax Court · 1973
- Lorenzo Alvary v. United StatesCourt of Appeals for the Second Circuit · 1962
- Harris v. CommissionerUnited States Tax Court · 1974
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