Legal Opinion

Goldberg v. Commissioner

United States Board of Tax Appeals

Decided January 17, 1928No. Docket No. 11615Published

1. A person may at the same time be regularly engaged in more than one kind of trade or business. 2. For 21 years prior to 1923 petitioner was regularly engaged in business as a wholesale liquor dealer. In the latter part of 1922 he ceased making purchases of additional stock but continued active efforts to sell and did sell during the year 1921 a quantity of the liquor on hand, from which he sustained a loss.

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1. A person may at the same time be regularly engaged in more than one kind of trade or business. 2. For 21 years prior to 1923 petitioner was regularly engaged in business as a wholesale liquor dealer. In the latter part of 1922 he ceased making purchases of additional stock but continued active efforts to sell and did sell during the year 1921 a quantity of the liquor on hand, from which he sustained a loss. Held, that this was a business regularly carried on during 1923 and the net loss sustained in the operation thereof was deductible from net income for the year 1924. 3. From 1915 to and…

1Opinion of the Court

LOUIS M. GOLDBERG, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Goldberg v. Commissioner

Docket No. 11615.

United States Board of Tax Appeals

9 B.T.A. 1355; 1928 BTA LEXIS 4229;

January 17, 1928, Promulgated

1. A person may at the same time be regularly engaged in more than one kind of trade or business.

2. For 21 years prior to 1923 petitioner was regularly engaged in business as a wholesale liquor dealer. In the latter part of 1922 he ceased making purchases of additional stock but continued active efforts to sell and did sell during the year 1921 a quantity of the liquor on hand,…

2Cases cited4 opinions

  1. Harrington v. CommissionerUnited States Board of Tax Appeals · 1924
  2. Schlesinger v. CommissionerUnited States Board of Tax Appeals · 1926
  3. Gutman v. CommissionerUnited States Board of Tax Appeals · 1927
  4. Goldberg v. CommissionerUnited States Board of Tax Appeals · 1928

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