Shepard v. Commissioner
United States Board of Tax Appeals
1. The taxpayer, without reference to his tax liability, settled through compromise an ad valorem penalty assessment, incurred through the irregular filing of his tax return for the year.
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1. The taxpayer, without reference to his tax liability, settled through compromise an ad valorem penalty assessment, incurred through the irregular filing of his tax return for the year. Held, that such settlement in no way affected his liability to further assessment for any additional taxes later determined for said year. 2. Evidence in support of deductions claimed for losses through investment in corporation stock and for a bad debt held insufficient to show loss sustained within the taxable year.
1Opinion of the Court
*629OPINION.
Lansdon:
Petitioner first assigns as error the Commissioner’s act in disallowing two deductions claimed for the taxable year — one in the amount of $34,506.81, representing a loss sustained upon corpora*630tion stock which became worthless during that year, and the other for a debt o'f $1,920 ascertained to be worthless and charged off within the year.
In respect to the first mentioned loss, the evidence establishes the fact that prior to the year in question petitioner was the owner of capital stock of a corporation which was in the final stages of liquidation through proceedings in…
2Cases cited7 opinions
- Nassoiy v. . TomlinsonNew York Court of Appeals · 1896
- Ryan v. . WardNew York Court of Appeals · 1872
- Claim of Davis v. Newsweek MagazineNew York Court of Appeals · 1953
- Armour & Co. v. Ross & BarfieldSupreme Court of Georgia · 1900
- Rogers v. Union Iron & Foundry Co.Missouri Court of Appeals · 1912
2 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Shepard v. CommissionerUnited States Board of Tax Appeals · 1929