Legal Opinion

Wade H. Cooper v. Commissioner

United States Tax Court

Decided September 7, 1951No. Docket No. 24322Unpublished

Held: (1) The shares of the capital stock of the United States Savings Bank of Washington, D.C., became worthless prior to the taxable year 1946; (2) in the taxable year 1946 petitioner realized net taxable income in the amount of $7,433.88, or the difference between the amount he paid certain creditors of the United States Savings Bank for an assignment of their respective claims and the amount he received from the Comptroller of the Currency in that year in payment of such…

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Held: (1) The shares of the capital stock of the United States Savings Bank of Washington, D.C., became worthless prior to the taxable year 1946; (2) in the taxable year 1946 petitioner realized net taxable income in the amount of $7,433.88, or the difference between the amount he paid certain creditors of the United States Savings Bank for an assignment of their respective claims and the amount he received from the Comptroller of the Currency in that year in payment of such claims.

1Opinion of the Court

Wade H. Cooper v. Commissioner.

Wade H. Cooper v. Commissioner

Docket No. 24322.

United States Tax Court

1951 Tax Ct. Memo LEXIS 109; 10 T.C.M. (CCH) 851; T.C.M. (RIA) 51268;

September 7, 1951

Held: (1) The shares of the capital stock of the United States Savings Bank of Washington, D.C., became worthless prior to the taxable year 1946; (2) in the taxable year 1946 petitioner realized net taxable income in the amount of $7,433.88, or the difference between the amount he paid certain creditors of the United States Savings Bank for an assignment of their respective claims and the amount he received…

2Cases cited5 opinions

  1. Commissioner v. JacobsonSupreme Court of the United States · 1949
  2. Helvering v. American Dental Co.Supreme Court of the United States · 1943
  3. Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
  4. United States Sav. Bank v. MorgenthauCourt of Appeals for the D.C. Circuit · 1936
  5. Cooper v. ParsonsCourt of Appeals for the D.C. Circuit · 1945

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