Von Hoffmann Corp. v. Commissioner
United States Tax Court
Petitioner sold all of the outstanding stock of a corporation to Smith. The corporation was indebted to petitioner in the amount of $65,000. Later petitioner assigned the $65,000 note to Smith for $500. Petitioner, on the same day as the assignment, charged off $64,500 as a bad debt loss. Held, petitioner was only entitled to a capital loss deduction under section 117(a)(1), Internal Revenue Code of 1939.
1Opinion of the Court
Von Hoffmann Corporation v. Commissioner.
Von Hoffmann Corp. v. Commissioner
Docket No. 62190.
United States Tax Court
T.C. Memo 1957-127; 1957 Tax Ct. Memo LEXIS 124; 16 T.C.M. (CCH) 546; T.C.M. (RIA) 57127;
July 11, 1957
Petitioner sold all of the outstanding stock of a corporation to Smith. The corporation was indebted to petitioner in the amount of $65,000. Later petitioner assigned the $65,000 note to Smith for $500. Petitioner, on the same day as the assignment, charged off $64,500 as a bad debt loss. Held, petitioner was only entitled to a capital loss deduction under section 117(a)(1),…
2Cases cited1 opinion
- Mitchell v. CommissionerUnited States Tax Court · 1949
3Cited by2 opinions
- Levine v. CommissionerUnited States Tax Court · 1959
- Levine v. CommissionerUnited States Tax Court · 1959