Legal Opinion

Byrum v. Commissioner

United States Tax Court

Decided August 1, 1972No. Docket No. 1435-71PublishedCited by 11 opinions

Held, petitioners established a prima facie case that their stock in Chappell Securities Corp. became worthless in 1967. They are entitled, under sec. 165, I.R.C. 1954, to a capital loss deduction for 1967 and a carryover of such deduction for 1968.

1Opinion of the Court

Featherston, Judge:

Respondent determined deficiencies in petitioners’ joint Federal income tax returns for 1967 and 1968 in the amounts of $1,005.92 and $4,571.79, respectively. Concessions having been made by the parties, the only issue for decision is whether the stock of petitioner Paul J. Byrum in Chappell Securities Corp. became worthless in 1967.

FINDINGS OF FACT

Paul J. Byrum (hereinafter referred to as petitioner) and Evelyn J. Byrum, husband and wife, were legal residents of Anderson, Ind., at the time they filed their petition. They filed their joint Federal income tax returns for…

2Cases cited5 opinions

  1. Boehm v. CommissionerSupreme Court of the United States · 1945
  2. Morton v. CommissionerUnited States Board of Tax Appeals · 1938
  3. Morton v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1940
  4. Andrew v. CommissionerUnited States Tax Court · 1970
  5. Blair v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1937

3Cited by11 opinions

  1. Estate of Gilford v. CommissionerUnited States Tax Court · 1987
  2. Larchmont Foundation, Inc. v. CommissionerUnited States Tax Court · 1979
  3. Suarez v. CommissionerUnited States Tax Court · 1974
  4. Allied Tube & Conduit Corp. v. CommissionerUnited States Tax Court · 1975
  5. Byrum v. CommissionerUnited States Tax Court · 1972

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