Averill v. Commissioner
United States Board of Tax Appeals
The petitioner, a man of large resources and actively interested in many businesses operated in his city, devoted the usual business hours of each day to his affairs, maintaining an office and employees. It was his practice to operate each business venture through a corporation and not as a personal venture. Through the failure of one of such corporations he sustained a loss.
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The petitioner, a man of large resources and actively interested in many businesses operated in his city, devoted the usual business hours of each day to his affairs, maintaining an office and employees. It was his practice to operate each business venture through a corporation and not as a personal venture. Through the failure of one of such corporations he sustained a loss. Held that such loss resulted from the business of petitioner and may be considered in computing the amount of a net loss under section 204 of the Revenue Act of 1921.
1Opinion of the Court
GLENN M. AVERILL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Averill v. Commissioner
Docket Nos. 28787, 40075.
United States Board of Tax Appeals
20 B.T.A. 1196; 1930 BTA LEXIS 1959;
October 8, 1930, Promulgated
The petitioner, a man of large resources and actively interested in many businesses operated in his city, devoted the usual business hours of each day to his affairs, maintaining an office and employees. It was his practice to operate each business venture through a corporation and not as a personal venture. Through the failure of one of such corporations he sustained a…
2Cases cited1 opinion
- Averill v. CommissionerUnited States Board of Tax Appeals · 1930