Legal Opinion

Ames v. Commissioner

United States Board of Tax Appeals

Decided November 17, 1924No. Docket Nos. 12, 13Published

A taxpayer owning all of the stock of a corporation, not a personal service corporation, may not deduct under the Revenue Act of 1918, as losses sustained in the business or as debts ascertained to be worthless, advances made to such corporation in the amount of the losses actually sustained by the corporation during a year so long as the corporation has net assets from which recovery in part is possible.

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A taxpayer owning all of the stock of a corporation, not a personal service corporation, may not deduct under the Revenue Act of 1918, as losses sustained in the business or as debts ascertained to be worthless, advances made to such corporation in the amount of the losses actually sustained by the corporation during a year so long as the corporation has net assets from which recovery in part is possible. Individual business expenses cleared through the books of a corporation are deductible on the part of the individual to whose business they relate.

1Opinion of the Court

Appeals of WINTHROP AMES, OFFICE OF WINTHROP AMES, INC.

Ames v. Commissioner

Docket Nos. 12, 13.

United States Board of Tax Appeals

1 B.T.A. 63; 1924 BTA LEXIS 256;

November 17, 1924, decided Submitted October 2, 1924.

A taxpayer owning all of the stock of a corporation, not a personal service corporation, may not deduct under the Revenue Act of 1918, as losses sustained in the business or as debts ascertained to be worthless, advances made to such corporation in the amount of the losses actually sustained by the corporation during a year so long as the corporation has net assets from which…

2Cases cited1 opinion

  1. Ames v. CommissionerUnited States Board of Tax Appeals · 1924

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