McIntosh v. Commissioner
United States Tax Court
1. Held, except for one share of stock of subchapter S corporation in which Sam McIntosh had a basis of $200, petitioners had no basis in their shares of stock of, or in any indebtedness owed to them by, the subchapter S corporation as of March 31, 1959; consequently, petitioners are not entitled to deduct their pro rata shares of the net operating loss of the company for its fiscal year ending March 31, 1959, except to the extent of the $200 mentioned above. 2.…
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1. Held, except for one share of stock of subchapter S corporation in which Sam McIntosh had a basis of $200, petitioners had no basis in their shares of stock of, or in any indebtedness owed to them by, the subchapter S corporation as of March 31, 1959; consequently, petitioners are not entitled to deduct their pro rata shares of the net operating loss of the company for its fiscal year ending March 31, 1959, except to the extent of the $200 mentioned above. 2. Non-negotiable notes received by Sam McIntosh in year of sale of his stock in corporation, which were not payable until subsequent…
1Opinion of the Court
Sam F. McIntosh and Nancy S. McIntosh v. Commissioner. William M. McIntosh, Jr. and Thanetta McIntosh v. Commissioner.
McIntosh v. Commissioner
Docket Nos. 2529-65, 2530-65.
United States Tax Court
T.C. Memo 1967-230; 1967 Tax Ct. Memo LEXIS 31; 26 T.C.M. (CCH) 1164; T.C.M. (RIA) 67230;
November 17, 1967
1. Held, except for one share of stock of subchapter S corporation in which Sam McIntosh had a basis of $200, petitioners had no basis in their shares of stock of, or in any indebtedness owed to them by, the subchapter S corporation as of March 31, 1959; consequently, petitioners are not entitled…
2Cases cited38 opinions
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Marcello v. CommissionerUnited States Tax Court · 1964
- Bedell v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1929
- Bertrand W. Cohn v. United States of America, William R. Kent v. United States of America, Louise C. Kent v. United StatesCourt of Appeals for the Sixth Circuit · 1958
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