Harper v. Commissioner
United States Board of Tax Appeals
1. A net loss sustained by the petitioner in 1924 was attributable to a trade or business regularly carried on by him and is a proper deduction in computing net income for the year 1925. 2. The amount of the said net loss determined.
1Opinion of the Court
*151OPINION.
McMahon :
The respondent concedes that the petitioner sustained a loss for the year 1924 and he has not asserted a deficiency for that year. So far as the petition purports to include the year 1924, it is dismissed for lack of jurisdiction. Cornelius Cotton Mills, 4 B. T. A. *152255; Anita M. Baldwin, 10 B. T. A. 1198; Marjorie Post Hutton, 12 B. T. A. 265.
The petitioner contends that the loss which ho sustained during 1924, as detailed in our findings of fact, was a loss “ attributable to the operation of a trade or business regularly carried on ” by him and that he is entitled to…
2Cases cited1 opinion
- Bryce v. KeithDistrict Court, E.D. New York · 1919
3Cited by1 opinion
- Harper v. CommissionerUnited States Board of Tax Appeals · 1930