Legal Opinion
Commissioner of Internal Revenue v. Spreckels
Court of Appeals for the Ninth Circuit
Decided June 12, 1941No. 9669PublishedCited by 18 opinions
1Opinion of the Court
GARRECHT, Circuit Judge.
The single question presented by this petition for review, as stated by the Board of Tax Appeals, is whether a transaction in which the taxpayer surrendered promissory notes and collateral security, in consideration of a deed to certain real estate, also mortgaged to her as security for the notes, resulted in a capital loss, an ordinary loss, or a bad debt.
The Board found the facts to be substantially as follows:
June 10, 1930, the taxpayer, a resident of San Francisco, California, loaned to her brother-in-law, Rudolph Spreckels, upon his promissory note, the sum of…
2Cases cited16 opinions
- Fairbanks v. United StatesSupreme Court of the United States · 1939
- Hale v. HelveringCourt of Appeals for the D.C. Circuit · 1936
- Bingham v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1939
- Electro-Chemical Engraving Co. v. CommissionerSupreme Court of the United States · 1941
- Rhodes v. CommissionerCourt of Appeals for the Sixth Circuit · 1939
11 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- National-Standard Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1984
- Hobson v. CommissionerUnited States Tax Court · 1951
- Reed v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1942
- Rogan v. Commercial Discount Co.Court of Appeals for the Ninth Circuit · 1945
- Markle v. CommissionerUnited States Tax Court · 1952
13 more not listed; retrieve them via the Exa API.