Legal Opinion

Parker v. Commissioner

United States Board of Tax Appeals

Decided February 10, 1939No. Docket No. 90260Published

JOINT VENTURE - DEDUCTION OF NONCAPITAL LOSS UNDER SECTION 23(r), REVENUE ACT OF 1932. - Petitioners, husband and wife, in 1933 established a so-called joint brokerage or trading account with funds supplied solely by the husband. The wife contributed neither capital nor services to the enterprise and took no part in its conduct. There was no agreement that she should share in the profits or losses.

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JOINT VENTURE - DEDUCTION OF NONCAPITAL LOSS UNDER SECTION 23(r), REVENUE ACT OF 1932. - Petitioners, husband and wife, in 1933 established a so-called joint brokerage or trading account with funds supplied solely by the husband. The wife contributed neither capital nor services to the enterprise and took no part in its conduct. There was no agreement that she should share in the profits or losses. Held, such account did not constitute a joint venture, but was in fact the individual account and property of the husband, and he is entitled to deduct the noncapital loss sustained in that account…

1Opinion of the Court

HAROLD G. PARKER AND MAY J. PARKER, HUSBAND AND WIFE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Parker v. Commissioner

Docket No. 90260.

United States Board of Tax Appeals

39 B.T.A. 423; 1939 BTA LEXIS 1039;

February 10, 1939, Promulgated

JOINT VENTURE - DEDUCTION OF NONCAPITAL LOSS UNDER SECTION 23(r), REVENUE ACT OF 1932. - Petitioners, husband and wife, in 1933 established a so-called joint brokerage or trading account with funds supplied solely by the husband. The wife contributed neither capital nor services to the enterprise and took no part in its conduct. There was no…

2Cases cited1 opinion

  1. Parker v. CommissionerUnited States Board of Tax Appeals · 1939

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