Legal Opinion
Commissioner of Internal Revenue v. Stokes' Estate
Court of Appeals for the Third Circuit
Decided January 7, 1953No. 10763PublishedCited by 33 opinions
1Opinion of the Court
MARIS, Circuit Judge.
The commissioner of Internal Revenue asks us to reverse a decision of the Tax Court holding that a debt owing to the petitioners’ decedent by the Pullenlite Company which became worthless in 1947 was deductible by the petitioners, in computing their decedent’s income tax liability for that year,- as a debt incurred in the decedent’s trade or business under Section 23 (k) (1) of the Internal Revenue Code. 26U.S.C. § 23(k) (1). The question whether the activities of a taxpayer constitute carrying on a trade or business is largely one of fact the solution of which “requires…
2Cases cited8 opinions
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Burnet v. ClarkSupreme Court of the United States · 1932
- Dalton v. BowersSupreme Court of the United States · 1932
- Campbell v. CommissionerUnited States Tax Court · 1948
- Cluett v. CommissionerUnited States Tax Court · 1947
3 more not listed; retrieve them via the Exa API.
3Cited by33 opinions
- Whipple v. CommissionerSupreme Court of the United States · 1963
- John M. Trent and Lisa M. Trent v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
- Vincent C. Giblin v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1955
- H. Beale Rollins and Mary E. Rollins v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- Rollins v. CommissionerUnited States Tax Court · 1959
28 more not listed; retrieve them via the Exa API.