Seymour v. Commissioner
United States Tax Court
1. Held, petitioner is not entitled to a deduction, either as a bad debt or as a loss, of the value of certain shares of stock awarded under a stock bonus plan where, under the plan's provisions, on the separation of petitioner from the company, the unearned portion of the shares was forfeited and the certificates not delivered. 2. Cost of installing an oil-heating furnace in taxpayer's home held not deductible as a medical expense. 3. Federal excise tax on jewelry and…
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1. Held, petitioner is not entitled to a deduction, either as a bad debt or as a loss, of the value of certain shares of stock awarded under a stock bonus plan where, under the plan's provisions, on the separation of petitioner from the company, the unearned portion of the shares was forfeited and the certificates not delivered. 2. Cost of installing an oil-heating furnace in taxpayer's home held not deductible as a medical expense. 3. Federal excise tax on jewelry and cigarettes and New York State and Ohio State taxes on cigarettes, held not deductible, since those taxes are not imposed upon…
1Opinion of the Court
OPINION.
Van Fossan, Judge-.
It is contended by petitioner that he is entitled to a bad debt deduction in the amount of $834.15 under section 23 (k) (1) of the Internal Eevenue Code. It is argued that the awards vested in petitioner all the rights of a stockholder, that the awards constituted a debt owed by the company to petitioner, and that the debt became a bad debt to the extent of the value of the 54%g shares at the time such shares were divested by the bonus custodian. It is also contended by petitioner that he is entitled to a deduction under section 23 (k) (2). It is argued that the…
2Cases cited3 opinions
- Havey v. CommissionerUnited States Tax Court · 1949
- Stringham v. CommissionerUnited States Tax Court · 1949
- O'Meara v. CommissionerUnited States Tax Court · 1947
3Cited by13 opinions
- Haines v. CommissionerUnited States Tax Court · 1979
- Edna G. Hollander v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1955
- Wallace v. United StatesDistrict Court, S.D. Iowa · 1970
- Worden v. CommissionerUnited States Tax Court · 1981
- Atwell v. CommissionerUnited States Tax Court · 1981
8 more not listed; retrieve them via the Exa API.