Legal Opinion

Byrum v. Commissioner

United States Tax Court

Decided August 1, 1972No. Docket No. 1435-71Published

Held, petitioners established a prima facie case that their stock in Chappell Securities Corp. became worthless in 1967. They are entitled, under sec. 165, I.R.C. 1954, to a capital loss deduction for 1967 and a carryover of such deduction for 1968.

1Opinion of the Court

Paul J. Byrum and Evelyn J. Byrum, Petitioners v. Commissioner of Internal Revenue, Respondent

Byrum v. Commissioner

Docket No. 1435-71

United States Tax Court

58 T.C. 731; 1972 U.S. Tax Ct. LEXIS 80;

August 1, 1972, Filed

Decision will be entered under Rule 50.

Held, petitioners established a prima facie case that their stock in Chappell Securities Corp. became worthless in 1967. They are entitled, under sec. 165, I.R.C. 1954, to a capital loss deduction for 1967 and a carryover of such deduction for 1968.

Daniel S. Davisson, for the petitioners.

Robert G. Martinell, for the respondent.

Featherston,…

2Cases cited6 opinions

  1. Boehm v. CommissionerSupreme Court of the United States · 1945
  2. Morton v. CommissionerUnited States Board of Tax Appeals · 1938
  3. Morton v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1940
  4. Andrew v. CommissionerUnited States Tax Court · 1970
  5. Blair v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1937

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