McNeill v. Commissioner
United States Tax Court
1. Deduction of loss realized by the owner of property upon seizure and sale for nonpayment of realty taxes to a corporation wholly owned by petitioner and his immediate family, held, precluded by section 24 (b) (1) (B), I. R. C. 1939, as a sale between related taxpayers. 2. Debts incurred by a practicing attorney, which became worthless during 1947, held, not proximately related to his professional activities and deductible only as nonbusiness bad debts subject to the…
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1. Deduction of loss realized by the owner of property upon seizure and sale for nonpayment of realty taxes to a corporation wholly owned by petitioner and his immediate family, held, precluded by section 24 (b) (1) (B), I. R. C. 1939, as a sale between related taxpayers. 2. Debts incurred by a practicing attorney, which became worthless during 1947, held, not proximately related to his professional activities and deductible only as nonbusiness bad debts subject to the limitations of section 23 (k) (4), I. R. C. 1939.
1Opinion of the Court
Withey, Judge:
The respondent determined deficiencies in petitioner’s income tax for the indicated years as follows:
Tear Deficiency
1946_ 82.762. 66
1947_ 2.096.86
The issues presented for our decision are the correctness of the respondent’s action (1) in disallowing a deduction claimed by petitioner as an abandonment loss in the amount of $11,000 arising from the sale of his land for nonpayment of taxes and (2) in determining that bad debts in the amount of $2,685 are deductible only as nonbusiness bad debts; An additional issue presented by the pleadings concerning the deductibility of medical…
2Cases cited17 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Thrift v. CommissionerUnited States Tax Court · 1950
- McWilliams v. CommissionerSupreme Court of the United States · 1947
- Dunlap, Acting Collector of Internal Revenue v. Oldham Lumber CoCourt of Appeals for the Fifth Circuit · 1950
- Bart v. CommissionerUnited States Tax Court · 1954
12 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Pachella v. CommissionerUnited States Tax Court · 1961
- Hassen v. CommissionerUnited States Tax Court · 1974
- Merritt v. CommissionerUnited States Tax Court · 1967
- Garlove v. CommissionerUnited States Tax Court · 1965
- Kurtz v. CommissionerUnited States Tax Court · 1985
8 more not listed; retrieve them via the Exa API.