C. A. Sporl & Co. v. Commissioner
United States Board of Tax Appeals
The petitioner in December 1933 sold at a loss bonds which it had received in February 1932 under a binding agreement entered into in October 1931. Held, that the loss was sustained from the sale of assets held more than two years, and that the deduction of the loss is not subject to the limitation of section 23(r) of the Revenue Act of 1932.
1Opinion of the Court
OPINION.
Smith:
This proceeding is for the redetermination of deficiencies in income and excess profits taxes for 1933 of $4,885.66 and $1,244.49, respectively. The question in issue is whether the petitioner sustained a deductible loss of $39,100 in 1933 on the sale to its president, Cyprian A. Sporl, Sr., of $46,000 par value second mortgage bonds of the Shipside Storage Co.
C. A. Sporl & Co., is a Louisiana corporation, with its principal office in New Orleans. It is engaged in the insurance brokerage business. Upon its organization it took over the business of a predecessor partnership.
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2Cases cited1 opinion
- McFeely v. CommissionerSupreme Court of the United States · 1935
3Cited by9 opinions
- George W. S. Swenson and Ruth E. Swenson v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962
- Swenson v. CommissionerUnited States Tax Court · 1961
- Wiles v. CommissionerUnited States Tax Court · 1973
- Commissioner v. C. A. Sporl & Co.Court of Appeals for the Fifth Circuit · 1941
- C. A. Sporl & Co. v. CommissionerUnited States Board of Tax Appeals · 1939
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