Cosgrove v. Commissioner
United States Tax Court
Petitioner and other investors formed Scott-Glenn Investments, Limited, in 1976 for the purpose of investing in Scotch whiskey receipts. After failure to receive SEC approval for the unregistered sale of such securities, Scott-Glenn ceased all attempts to do business. Held: the requirements of the regulations under section 1244 have not been complied with and petitioner is not entitled to a $ 10,000 ordinary loss.
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Petitioner and other investors formed Scott-Glenn Investments, Limited, in 1976 for the purpose of investing in Scotch whiskey receipts. After failure to receive SEC approval for the unregistered sale of such securities, Scott-Glenn ceased all attempts to do business. Held: the requirements of the regulations under section 1244 have not been complied with and petitioner is not entitled to a $ 10,000 ordinary loss. Held further: petitioner is liable for an addition to tax under sec. 6651(a)(1).
1Opinion of the Court
JOSEPH P. AND M. CATHERINE COSGROVE, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Cosgrove v. Commissioner
Docket No. 25352-83.
United States Tax Court
T.C. Memo 1987-401; 1987 Tax Ct. Memo LEXIS 398; 54 T.C.M. (CCH) 136; T.C.M. (RIA) 87401;
August 17, 1987.
Petitioner and other investors formed Scott-Glenn Investments, Limited, in 1976 for the purpose of investing in Scotch whiskey receipts. After failure to receive SEC approval for the unregistered sale of such securities, Scott-Glenn ceased all attempts to do business. Held: the requirements of the regulations under section 1244…
2Cases cited10 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Taylor v. CommissionerUnited States Tax Court · 1977
- Morgan v. CommissionerUnited States Tax Court · 1966
- Cary v. CommissionerUnited States Tax Court · 1963
- Schad v. CommissionerUnited States Tax Court · 1986
5 more not listed; retrieve them via the Exa API.
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