Legal Opinion

Moore v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided February 18, 1953No. 14106_1PublishedCited by 10 opinions

1Opinion of the Court

HUTCHESON, Chief Judge.

Complaining of the decisions 1 of the tax court disallowing, 2 under Sec. 24(b) (1) (B), I.R.C., 26 U.S.C.A. § 24(b) (1) (B), claimed losses bn ap exchange of properties with a corporation of which they became sole stockholders simultaneously with consummation of the exchange, and determining deficiencies in income and victory taxes for the year 1943 accordingly, petitioners are here insisting that the decisions are erroneous and must be reversed.

Two grounds for reversal are put forward. One goes to the substance of the decisions. It is that, under the facts as…

2Cases cited4 opinions

  1. General Utilities & Operating Co. v. HelveringSupreme Court of the United States · 1935
  2. WA Drake, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Tenth Circuit · 1944
  3. Hay v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1944
  4. Anderson v. CommissionerCourt of Appeals for the Second Circuit · 1946

3Cited by10 opinions

  1. Tracinda Corp. v. CommissionerUnited States Tax Court · 1998
  2. Federal Cement Title Co. v. CommissionerUnited States Tax Court · 1963
  3. Stern v. CommissionerUnited States Tax Court · 1953
  4. Estate of Roberts v. CommissionerUnited States Tax Court · 1972
  5. Royal Little v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1960

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