CLuck v. Commissioner
United States Tax Court
Deductions -- Net Operating Loss -- Termination of Part [ILLEGIBLE WORD] Business -- Sec. 122 (d) (5), I. R. C. 1939. -- The loss sustained on the sale of a herd of breeding cattle which had contracted Bang's disease was not a net operating loss "attributable to the operation of a trade or business regularly carried on" since breeding operations were thereby terminated.
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Deductions -- Net Operating Loss -- Termination of Part [ILLEGIBLE WORD] Business -- Sec. 122 (d) (5), I. R. C. 1939. -- The loss sustained on the sale of a herd of breeding cattle which had contracted Bang's disease was not a net operating loss "attributable to the operation of a trade or business regularly carried on" since breeding operations were thereby terminated. The loss sustained on the sale of a combine was a net operating loss since it did not result in any substantial diminution of the farming business in which it had been used and was made in the ordinary course of the operation…
1Opinion of the Court
Gene Cluck, Vivian Cluck, Petitioners, v. Commissioner of Internal Revenue, Respondent
CLuck v. Commissioner
Docket No. 54527
United States Tax Court
29 T.C. 7; 1957 U.S. Tax Ct. LEXIS 69;
October 9, 1957, Filed
Decision will be entered under Rule 50.
Deductions -- Net Operating Loss -- Termination of Part [ILLEGIBLE WORD] Business -- Sec. 122 (d) (5), I. R. C. 1939. -- The loss sustained on the sale of a herd of breeding cattle which had contracted Bang's disease was not a net operating loss "attributable to the operation of a trade or business regularly carried on" since breeding operations were…
Also in this document: Dissent.
2Cases cited18 opinions
- Dalton v. BowersSupreme Court of the United States · 1932
- Albright v. United StatesCourt of Appeals for the Eighth Circuit · 1949
- Fawn Lake Ranch Co. v. Comm'rUnited States Tax Court · 1949
- Lazier v. United StatesCourt of Appeals for the Eighth Circuit · 1948
- Sic v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1949
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