Potter v. Commissioner
United States Board of Tax Appeals
1. NET LOSS. - Upon the evidence petitioner is held to have sustained for the calendar year 1923 a net loss, as defined by section 204 of the Revenue Act of 1921, in the regular carrying on of his business of organizing, incorporating, capitalizing and actively conducting and operating hotel properties, and to be entitled, under section 206 of the Revenue Act of 1924, to deduct the amount thereof in computing net income for the calendar years 1924 and 1925. 2. EXPENSES. -…
Read the full summary
1. NET LOSS. - Upon the evidence petitioner is held to have sustained for the calendar year 1923 a net loss, as defined by section 204 of the Revenue Act of 1921, in the regular carrying on of his business of organizing, incorporating, capitalizing and actively conducting and operating hotel properties, and to be entitled, under section 206 of the Revenue Act of 1924, to deduct the amount thereof in computing net income for the calendar years 1924 and 1925. 2. EXPENSES. - Certain expenses of travel by petitioner in the years 1924 and 1925 found to be reasonable and necessary for business…
1Opinion of the Court
*552OPINION.
Trussell:
Under the first issue we have for consideration the character of a loss sustained in 1923 by petitioner in the sale of certain stock, the amount of the loss carried forward to 1924 and 1925 by petitioner being shown and the correctness of this amount and the fact that it is 1923 loss allowed by respondent for that year not being in issue. The sole question on this issue is whether the loss sustained in 1923 was a net loss subject to be carried forward and deducted over the two succeeding taxable years 1924 and 1925. In determining this question of law the applicable provision…
2Cases cited3 opinions
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Von Baumbach v. Sargent Land Co.Supreme Court of the United States · 1917
- The Parker Mills v. . the Commissioners of TaxesNew York Court of Appeals · 1861
3Cited by6 opinions
- Wallace v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1944
- McNeir v. CommissionerUnited States Board of Tax Appeals · 1934
- Piggly Wiggly Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
- Anthony v. CommissionerUnited States Board of Tax Appeals · 1930
- Piggly Wiggly Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
1 more not listed; retrieve them via the Exa API.