Putnam v. Commissioner
United States Board of Tax Appeals
Petitioner's husband, the owner of certain corporate notes aggregating $142,000, gave to petitioner $72,000 thereof in 1928, which she sold for $1 and obtained a deduction accordingly in her income tax for that year.
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Petitioner's husband, the owner of certain corporate notes aggregating $142,000, gave to petitioner $72,000 thereof in 1928, which she sold for $1 and obtained a deduction accordingly in her income tax for that year. In 1929, the taxable year, the husband, to obtain a like result, gave to petitioner the remaining $70,000 of the notes, which she likewise sold for $1. Held, the claim by petitioner for a deductible loss for 1929 on this account is cognizable only under the worthless debt provisions of the statute, and, as the notes were ascertained to be worthless in 1928, the respondent…
1Opinion of the Court
OPINION.
Seawell:
Respondent determined a deficiency in the income tax of petitioner for the year 1929 in the sum of $17,317.78, of which sum $8,749.87 is in controversy. The controversy arises from the disallowance by the respondent of a claimed deductible loss of $69,999, subject to the provisions of section 101 of the Revenue Act of 1928, resulting from the sale of certain notes, aggregating $70,000, of the Newfield Corporation sold by petitioner in the taxable year for $1.
Petitioner is the wife of George Putnam and they are citizens and residents of Manchester, Massachusetts. George Putnam…
2Cases cited4 opinions
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Hill v. International Products Co.New York Supreme Court · 1925
- Ames v. CommissionerUnited States Board of Tax Appeals · 1933
- Spring City Foundry Co. v. CommissionerUnited States Board of Tax Appeals · 1932
3Cited by4 opinions
- James A. Messer Co. v. CommissionerUnited States Tax Court · 1972
- James A. Messer Co. v. CommissionerUnited States Tax Court · 1972
- Putnam v. CommissionerUnited States Board of Tax Appeals · 1934
- Withington v. CommissionerUnited States Tax Court · 1944