Piggly Wiggly Corp. v. Commissioner
United States Board of Tax Appeals
1. Held, the money which petitioner's president invested in stock of a licensee corporation in 1922 and, which, while so invested, was lost through embezzlement and conversion by said president, was a loss sustained in the prosecution of its regular business in 1922. 2, Held, under the facts shown, the several items which entered into a judgment balance which a Federal court found was due the taxpayer from its president, on account of overdrafts and unlawful withdrawals of…
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1. Held, the money which petitioner's president invested in stock of a licensee corporation in 1922 and, which, while so invested, was lost through embezzlement and conversion by said president, was a loss sustained in the prosecution of its regular business in 1922. 2, Held, under the facts shown, the several items which entered into a judgment balance which a Federal court found was due the taxpayer from its president, on account of overdrafts and unlawful withdrawals of its funds made by him in conducting its business, were lost to it respectively, as and when the various withdrawals and…
1Opinion of the Court
*416OPINION.
Lansdon:
In their stipulation of facts the parties to this dispute have agreed that the petitioner suffered losses of various characters in the aggregate of $2,137,155.84 and that this sum is composed of items which they have classified in three groups, as follows:(a) $201,433.48 represents the so-called misappropriated or embezzled funds not discharged in bankruptcy.(b) $700,216.52 represents the amount that the court held was legally expended by Saunders on marginal accounts for the petitioner, which subsequently became lost.(c) $1,235,505.84 represents the amounts expended by…
2Cases cited9 opinions
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Peterson Linotyping Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Stern v. CommissionerUnited States Board of Tax Appeals · 1926
- Douglas County Light & Water Co. v. CommissionerUnited States Board of Tax Appeals · 1929
- Elliott v. CommissionerUnited States Board of Tax Appeals · 1929
4 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Piggly Wiggly Corp. v. CommissionerUnited States Board of Tax Appeals · 1933