Adnee v. Commissioner
United States Tax Court
Partnership, engaged in the real estate subdivision business, had surplus funds as a result of adverse zoning in respect of part of its property, and determined to use such funds in securities speculation. It bought and sold securities and made short sales of securities, for its own account, through a licensed broker. Held, the net loss of $ 114,115.59 which it sustained from all such trading in the year ending March 31, 1959, was a capital loss and not an ordinary loss.
1Opinion of the Court
Harry M. Adnee and Margaret P. Adnee, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Adnee v. Commissioner
Docket Nos. 94686, 94687, 94688
United States Tax Court
41 T.C. 40; 1963 U.S. Tax Ct. LEXIS 39;
October 10, 1963, Filed
Decisions will be entered for the respondent.
Partnership, engaged in the real estate subdivision business, had surplus funds as a result of adverse zoning in respect of part of its property, and determined to use such funds in securities speculation. It bought and sold securities and made short sales of securities, for its own account, through a…
2Cases cited5 opinions
- Schafer v. HelveringSupreme Court of the United States · 1936
- Schafer v. HelveringCourt of Appeals for the D.C. Circuit · 1936
- Commissioner of Internal Revenue v. BurnettCourt of Appeals for the Fifth Circuit · 1941
- Burnett v. CommissionerUnited States Board of Tax Appeals · 1939
- Adnee v. CommissionerUnited States Tax Court · 1963