Legal Opinion
Erwin E. Hassen and Estate of Birdie B. Hassen, Deceased, Nathan Hassen, Administrator v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided June 25, 1979No. 77-2298PublishedCited by 14 opinions
1Opinion of the Court
FERGUSON, District Judge:
This is an appeal from a decision of the United States Tax Court which held that appellants’ claimed deduction of a loss of $477,825.44 was barred by Section 267(a)(1) of the Internal Revenue Code. We hold that the tax court properly disallowed the loss. 63 T.C. 175 (1974).
FACTS
The facts are not in dispute. The parties stipulated to them in the tax court and they are, in relevant part, set forth below.
On March 18, 1955, Erwin E. Hassen and Birdie B. Hassen (the “Hassens”) purchased Golden State Hospital (“Golden State”) for $975,000. Although the property was a…
2Cases cited8 opinions
- Commissioner v. GordonSupreme Court of the United States · 1968
- McWilliams v. CommissionerSupreme Court of the United States · 1947
- American Bantam Car Co. v. CommissionerUnited States Tax Court · 1948
- Robert H. McNeill v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1958
- McCarty v. Cripe, Collector of Internal RevenueCourt of Appeals for the Seventh Circuit · 1953
3 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Davis v. CommissionerUnited States Tax Court · 1987
- Frank C. Davis, Jr. And Frank C. Davis, Jr., of the Estate of Grace K. Davis v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989
- Unionbancal Corp. v. CommissionerUnited States Tax Court · 1999
- Tracinda Corp. v. CommissionerUnited States Tax Court · 1998
- Miller v. CommissionerUnited States Tax Court · 1980
9 more not listed; retrieve them via the Exa API.