Steinback v. Commissioner
United States Board of Tax Appeals
Deduction - Loss on Worthless Stock. - Respondent disallowed a claimed loss deduction for 1929 upon a finding that petitioner's stock became worthless in 1928, the year in which the corporation was adjudged insolvent.
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Deduction - Loss on Worthless Stock. - Respondent disallowed a claimed loss deduction for 1929 upon a finding that petitioner's stock became worthless in 1928, the year in which the corporation was adjudged insolvent. Petitioner failed to prove that the stock was not worthless in 1928. Held, the fact that until 1929 petitioner entertained hopes of effecting a reorganization and made unsuccessful efforts to bring those hopes into being, is not a sufficient basis upon which to conclude that the stock was not worthless in 1928 and became worthless when such hopes were abandoned in 1929.
1Opinion of the Court
OPINION.
Leech:
Petitioner seeks redetermination of an income tax deficiency in the amount of $8,618.67 for the calendar year 1929, asserted by respondent due to his disallowance of a claimed loss deduction amounting to $60,024.27.
Respondent, by his answer, affirmatively avers that one item of income reported in the return in the amount of $71,524.90 as gain from the sale of real estate in 1929, should be increased to $94,024.96 and asserts claim for an increase in the above mentioned deficiency. Petitioner’s reply to the answer denies such averment. At the hearing respondent conceded the…
2Cases cited1 opinion
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
3Cited by4 opinions
- Pryibil v. CommissionerUnited States Board of Tax Appeals · 1934
- Bair v. United StatesDistrict Court, E.D. Pennsylvania · 1937
- Schoenhut v. CommissionerUnited States Board of Tax Appeals · 1941
- Steinback v. CommissionerUnited States Board of Tax Appeals · 1934