Legal Opinion

Coen v. Commissioner

United States Board of Tax Appeals

Decided February 20, 1930No. Docket No. 23173PublishedCited by 1 opinion

Loss sustained in 1921 held not "resulting from the operation of a trade or business regularly carried on by the taxpayer," and not deductible in 1922 as a net loss under section 204, Revenue Act of 1921.

1Opinion of the Court

*1277OPINION.

Steekhagen :

The losses sustained by petitioner in 1921 in respect of the Steel Co. and the Wyoming oil association were not “ losses resulting from the operation of a trade or business regularly carried on by the taxpayer ” and are not such as may, under section 204, Revenue Act of 1921, be carried into 1922. Fridolin Pabst, 6 B. T. A. 843; affd., 36 Fed. (2d) 614; Louis M. Goldberg, 9 B. T. A. 1355; affd., 36 Fed. (2d) 551; Harry J. Gutman, 7 B. T. A. 500; W. C. Harris, 8 B. T. A. 1234; J. L. Washburn, 16 B. T. A. 1091, now on review by Circuit Court of Appeals, Eighth Circuit.

Decisio…

2Cases cited2 opinions

  1. Mente v. EisnerCourt of Appeals for the Second Circuit · 1920
  2. Bryce v. KeithDistrict Court, E.D. New York · 1919

3Cited by1 opinion

  1. Coen v. CommissionerUnited States Board of Tax Appeals · 1930

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