Clark v. Commissioner of Internal Revenue

The taxpayer claims that he is entitled under Section 117(d) (2) and (e) (1) of the Internal Revenue Code, 26 U.S.C.A. § 117 (d) (2), (e) (1), to carry over to the year 1945 a loss resulting from a nonbusiness bad debt that became worthless in the year 1943, Internal Revenue Code, § 23 (k) (4), 26 U.S.C.A. § 23(k) (4). In 1937 he advanced $15,000 to his wife to purchase the voting trust certificate of the entire outstanding capital stock of The Nation, Inc. The taxpayer assisted his wife because of her desire that The Nation — a weekly magazine- — continue to be published in accordance with…