Legal Opinion

Crawford v. Commissioner

United States Board of Tax Appeals

Decided May 11, 1928No. Docket Nos. 6045, 6933PublishedCited by 9 opinions

The repayment during the taxable years of monies borrowed on behalf of petitioner in prior years for expanding and carrying on his business, held not to constitute deductible losses.

1Opinion of the Court

*1301OPINION.

Trammell :

The question here involved is whether the petitioner is entitled to deductions on account of notes paid in connection with the liquidation of Crawford & Eberman in 1918 and 1919, he being on a cash receipts and disbursements basis, or whether the losses were sustained in prior years.

The monies represented by the notes were secured in years prior to the taxable years, invested in the business and were lost, in any event, when the business ceased operations in 1917 if not prior thereto. None of the monies secured by the notes was used to pay debts or obligations of the firm…

2Cited by9 opinions

  1. OSBORNE v. COMMISSIONERUnited States Tax Court · 2002
  2. Smiling v. Comm'rUnited States Tax Court · 2017
  3. Briggs v. CommissionerUnited States Tax Court · 2000
  4. Brown v. Comm'rUnited States Tax Court · 2007
  5. Clark v. CommissionerUnited States Tax Court · 1994

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