Ammann v. Commissioner
United States Tax Court
Sec. 117 (j) (2), I. R. C., 1939. -- Partnership Loss and Individual Gain. -- Partnership long-term losses from noncapital assets became ordinary losses of partnership under section 117 (j) of the Internal Revenue Code of 1939 in computing its distributable income where partnership had no section 117 (j) gains, and a partner's share of such losses does not offset his long-term gains from individually owned noncapital assets.
1Opinion of the Court
Jack Jordan Ammann and Dorothy Lee Ammann, Petitioners, v. Commissioner of Internal Revenue, Respondent
Ammann v. Commissioner
Docket No. 41050
United States Tax Court
22 T.C. 1106; 1954 U.S. Tax Ct. LEXIS 118;
August 26, 1954, Filed August 26, 1954, Filed
Decision will be entered under Rule 50.
Sec. 117 (j) (2), I. R. C., 1939. -- Partnership Loss and Individual Gain. -- Partnership long-term losses from noncapital assets became ordinary losses of partnership under section 117 (j) of the Internal Revenue Code of 1939 in computing its distributable income where partnership had no section 117 (j)…
2Cases cited3 opinions
- Bentex Oil Corp. v. CommissionerUnited States Tax Court · 1953
- Scherf v. CommissionerUnited States Tax Court · 1953
- Ammann v. CommissionerUnited States Tax Court · 1954