Sales v. Commissioner
United States Tax Court
Petitioner Leona Sales was a partner in Stuart Enterprises, which by its articles of partnership was formed for the purpose of holding and renting real estate and "such other business and enterprises" as the partners would agree upon. The partnership made a loan of $ 120,000 to a corporation engaged in the manufacture and sale of a liquid hair spray.
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Petitioner Leona Sales was a partner in Stuart Enterprises, which by its articles of partnership was formed for the purpose of holding and renting real estate and "such other business and enterprises" as the partners would agree upon. The partnership made a loan of $ 120,000 to a corporation engaged in the manufacture and sale of a liquid hair spray. When the debt became worthless in 1955 the partnership took a bad debt deduction in computing its income tax, which resulted in a net operating loss for that year. Leona took a deduction on her individual return for her proportionate share of…
1Opinion of the Court
Fat, Judge:
The Commissioner determined a deficiency in petitioners’ income tax for 1955 of $2,224.31.1 The sole question for decision is the character of a loss sustained by a partnership in 1955.
FINDINGS OF FACT.
Some of the facts have been stipulated and they are found accordingly.
Petitioners Stuart M. and Leona Terry Sales are husband and wife residing in Louisville, Kentucky. They filed a timely joint Federal income tax return for the taxable year 1955 with the district director of internal revenue for the district of Kentucky. (An amended 1955 return was filed on June 6,1956, for a reason…
2Cases cited11 opinions
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Towers v. CommissionerUnited States Tax Court · 1955
- Langdon L. Skarda, Carolyn A. Skarda, Lynell G. Skarda, Kathryn B. Skarda, Cash T. Skarda and Annabel S. Skarda v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1957
- Cluett v. CommissionerUnited States Tax Court · 1947
- Skarda v. CommissionerUnited States Tax Court · 1956
6 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Imel v. CommissionerUnited States Tax Court · 1973
- Smith v. CommissionerUnited States Tax Court · 1970
- Estate of Byers v. CommissionerUnited States Tax Court · 1972
- Betts v. CommissionerUnited States Tax Court · 1974
- Lee v. CommissionerUnited States Tax Court · 1986
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