Martin v. Commissioner
United States Board of Tax Appeals
Petitioners were directors of a corporation which sold certain stock upon which its customers sustained losses. Feeling morally bound to protect the customers, and fearing that criticism of their institution and themselves for having sold the stock would react unfavorably, they agreed among themselves, and so notified the customers, to indemnify them.
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Petitioners were directors of a corporation which sold certain stock upon which its customers sustained losses. Feeling morally bound to protect the customers, and fearing that criticism of their institution and themselves for having sold the stock would react unfavorably, they agreed among themselves, and so notified the customers, to indemnify them. Under the same agreement they engaged, as a syndicate, in trading on the market and the profits thus derived were applied to buying up the stock from the customers. Held, the loss sustained upon the purchase of the stock from the customers is…
1Opinion of the Court
OPINION.
Goodrich :
In these proceedings, which were consolidated for hearing, the following deficiencies in income tax for 1928 are in controversy:
Doclcet No. Amount
53837_$1, 058. 25
53838_ 5, 354. 54
53839_ 17, 097. 57
53840_1_ 3,300.05
There is but one issue, namely, whether each of petitioners may deduct from his income his pro rata share of a loss sustained by a *742syndicate of which he was a member, upon the sale of stock of the Standard Publishing Co. The determination of that issue depends upon whether the loss was “ incurred in any transaction entered into for profit, though not connected…
2Cases cited2 opinions
- Vaughan v. CommissionerUnited States Board of Tax Appeals · 1929
- Goldsborough v. CommissionerUnited States Board of Tax Appeals · 1929
3Cited by1 opinion
- Martin v. CommissionerUnited States Board of Tax Appeals · 1933