Legal Opinion
Phipps v. Helvering
Court of Appeals for the D.C. Circuit
Decided December 8, 1941No. 7759PublishedCited by 4 opinions
1Opinion of the Court
VINSON, Associate Justice.
This case raises a question of deductible loss under Section 23(e) of the 1932 Revenue Act, 26 U.S.C.A. Int.Rev.Acts, page 490, which provides, inter alia, that an individual may deduct from his gross income, losses incurred in trade or business, or incurred in any transactions entered into for profit. The Commissioner and the Board of Tax Appeals did not allow a deduction.
Since 1904, the taxpayer, the Honorable Lawrence C. Phipps, has been buying, improving, renting, and selling real estate. His extensive holdings, for the most part, are in his own name or in that…
2Cases cited10 opinions
- Heiner v. TindleSupreme Court of the United States · 1928
- Schmidlapp v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1938
- Cecil v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1939
- Rumsey v. CommissionerCourt of Appeals for the Second Circuit · 1936
- Morgan v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Fifth Circuit · 1935
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3Cited by4 opinions
- Jones v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1945
- Robinson v. CommissionerCourt of Appeals for the Third Circuit · 1943
- United States v. Zelma T. Kyle and Betty K. KyleCourt of Appeals for the Fourth Circuit · 1957
- Kaczmarek v. CommissionerUnited States Tax Court · 1975