Hanna v. Commissioner
United States Tax Court
Losses on Sales or Exchanges Between Related Taxpayers -- Sec. 267, I.R.C. 1954. -- Held, no loss is allowable resulting from the redemption of stock by a corporation from a decedent's estate when all the stock of the corporation is owned by the estate and its beneficiaries who are sisters.
1Opinion of the Court
opinion.
Testjens, Judge:
The Commissioner determined a deficiency in income tax in the amount of $11,279.78 for the year 1958. The sole issue presented is whether a loss resulting from the redemption of stock by a corporation from a decedent’s estate is deductible by the estate when all the stock of the corporation is owned by the estate and its beneficiaries who are sisters.
The National City Bank of Cleveland is the duly appointed, qualified, and acting executor of the estate of Buth Hanna, deceased, under the appointment of the Probate Court of Cuyahoga County, Ohio. Its principal office is…
2Cases cited3 opinions
- Lexmont Corp. v. CommissionerUnited States Tax Court · 1953
- Ingalls v. CommissionerUnited States Board of Tax Appeals · 1941
- Clark v. CommissionerCourt of Appeals for the Sixth Circuit · 1943
3Cited by4 opinions
- Walter Bernard McCall and Marie S. McCall Sam G. McCall and Ruth W. McCall v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963
- Edward J. McCarthy and Lora R. McCarthy v. Joseph J. Conley, Jr., District Director of Internal Revenue for the Districtof ConnecticutCourt of Appeals for the Second Circuit · 1965
- Estate of Ruth Hanna, Deceased, the National City Bank of Cleveland v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1963
- Hanna v. CommissionerUnited States Tax Court · 1961