Legal Opinion

Jones v. Commissioner

United States Board of Tax Appeals

Decided March 31, 1930No. Docket No. 36119Published

A loss sustained by petitioner in the year 1923 as a result of the liquidation of a corporation, organized to carry on a business in which he was engaged, was not a "net loss" from the operation of a trade or business regularly carried on by him and the excess of the loss sustained in the year 1923 over his income for that year was not a proper deduction under the provisions of section 206 (f) of the Revenue Act of 1924 from his income for the taxable period, January 1 to…

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A loss sustained by petitioner in the year 1923 as a result of the liquidation of a corporation, organized to carry on a business in which he was engaged, was not a "net loss" from the operation of a trade or business regularly carried on by him and the excess of the loss sustained in the year 1923 over his income for that year was not a proper deduction under the provisions of section 206 (f) of the Revenue Act of 1924 from his income for the taxable period, January 1 to August 31, 1924.

1Opinion of the Court

A. LYNTON JONES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Jones v. Commissioner

Docket No. 36119.

United States Board of Tax Appeals

19 B.T.A. 447; 1930 BTA LEXIS 2395;

March 31, 1930, Promulgated

A loss sustained by petitioner in the year 1923 as a result of the liquidation of a corporation, organized to carry on a business in which he was engaged, was not a "net loss" from the operation of a trade or business regularly carried on by him and the excess of the loss sustained in the year 1923 over his income for that year was not a proper deduction under the provisions of section…

2Cases cited9 opinions

  1. Regal Shoe Co. v. CommissionerUnited States Board of Tax Appeals · 1925
  2. Eysenbach v. CommissionerUnited States Board of Tax Appeals · 1928
  3. Harrington v. CommissionerUnited States Board of Tax Appeals · 1924
  4. Schlesinger v. CommissionerUnited States Board of Tax Appeals · 1926
  5. Gutman v. CommissionerUnited States Board of Tax Appeals · 1927

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