Legal Opinion

Belser v. Commissioner

United States Tax Court

Decided June 7, 1948No. Docket No. 97873Published

1. The taxpayer purchased all the shares of a corporation which acquired two farms and he thereafter made loans and advances to the corporation. Prior to 1932 the corporation had divested itself of the farms, retaining no assets, and mortgages on the farms, securing the taxpayer's loans, had been extinguished.

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1. The taxpayer purchased all the shares of a corporation which acquired two farms and he thereafter made loans and advances to the corporation. Prior to 1932 the corporation had divested itself of the farms, retaining no assets, and mortgages on the farms, securing the taxpayer's loans, had been extinguished. The cost of the shares and the amount of the loans, held, not deductible in 1932 because shares and loans became worthless in prior years. 2. The taxpayer, a lawyer, was appointed special counsel for a state railroad commission at an annual salary. He continued his private law practice…

1Opinion of the Court

Irvine F. Belser, Petitioner, v. Commissioner of Internal Revenue, Respondent

Belser v. Commissioner

Docket No. 97873

United States Tax Court

10 T.C. 1031; 1948 U.S. Tax Ct. LEXIS 168;

June 7, 1948, Promulgated

Decision will be entered under Rule 50.

1. The taxpayer purchased all the shares of a corporation which acquired two farms and he thereafter made loans and advances to the corporation. Prior to 1932 the corporation had divested itself of the farms, retaining no assets, and mortgages on the farms, securing the taxpayer's loans, had been extinguished. The cost of the shares and the amount of…

2Cases cited12 opinions

  1. Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
  2. Graves v. New York Ex Rel. O'KeefeSupreme Court of the United States · 1939
  3. Helvering v. GerhardtSupreme Court of the United States · 1938
  4. O'Meara v. CommissionerUnited States Tax Court · 1947
  5. Broad River Power Co. v. South Carolina Ex Rel. DanielSupreme Court of the United States · 1930

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