Oster v. Commissioner
United States Tax Court
Held, that petitioner was not engaged in a trade or business of organizing and promoting corporations and that gains and losses resulting from the sale by him of stock of corporations received by him, upon the organization of such corporations, in exchange for mining claims, constituted capital gains and losses, and not ordinary gains and losses.
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Held, that petitioner was not engaged in a trade or business of organizing and promoting corporations and that gains and losses resulting from the sale by him of stock of corporations received by him, upon the organization of such corporations, in exchange for mining claims, constituted capital gains and losses, and not ordinary gains and losses. Held, further, that various expenditures made by petitioner on behalf of corporations in which he held interests are not deductible by him as ordinary and necessary expenses under section 212 of the Internal Revenue Code of 1954. Held, further, that…
1Opinion of the Court
Charles Oster v. Commissioner.
Oster v. Commissioner
Docket No. 92833.
United States Tax Court
T.C. Memo 1964-335; 1964 Tax Ct. Memo LEXIS 2; 23 T.C.M. (CCH) 2072; T.C.M. (RIA) 64335;
December 30, 1964
Held, that petitioner was not engaged in a trade or business of organizing and promoting corporations and that gains and losses resulting from the sale by him of stock of corporations received by him, upon the organization of such corporations, in exchange for mining claims, constituted capital gains and losses, and not ordinary gains and losses.
Held, further, that various expenditures made by…
2Cases cited24 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- United States v. GilmoreSupreme Court of the United States · 1963
- Whipple v. CommissionerSupreme Court of the United States · 1963
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