Goldner v. Commissioner
United States Tax Court
Petitioner, a majority stockholder in a corporation located in Budapest, Hungary, made advancements to the corporation in 1939 to be used in the corporation's operations. Petitioner was absent from Hungary during the years 1941 to 1948. In 1946 the corporation distributed a quantity of veneers to the taxpayer, which veneers were never moved from Budapest. In 1948, the Hungarian Government nationalized both the corporation's remaining assets and the veneers.
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Petitioner, a majority stockholder in a corporation located in Budapest, Hungary, made advancements to the corporation in 1939 to be used in the corporation's operations. Petitioner was absent from Hungary during the years 1941 to 1948. In 1946 the corporation distributed a quantity of veneers to the taxpayer, which veneers were never moved from Budapest. In 1948, the Hungarian Government nationalized both the corporation's remaining assets and the veneers. Held, the advances made by the petitioner to the corporation in 1939 were contributions to capital and therefore additions to the basis…
1Opinion of the Court
OPINION.
MulRoney, Judge:
The principal issues are whether the petitioner is entitled to a long-term capital loss deduction of $34,147.601 in 1948 under section 23(g) of the 1939 Internal Revenue Code through the worthlessness of stock owned by him in a corporation located in Budapest, Hungary, and whether he is entitled to a deduction in 1948 under section 23(e) of the 1939 Internal Revenue Code for the loss in that year of certain veneers owned by him in Budapest, Hungary.
As shown in the foregoing Findings of Fact, petitioner and his two brothers established the corporation in 1933 for the…
2Cases cited7 opinions
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Kaplan v. CommissionerUnited States Tax Court · 1953
- Sackstein v. CommissionerUnited States Tax Court · 1950
- Bachrach v. CommissionerUnited States Tax Court · 1952
- Kenmore v. CommissionerUnited States Tax Court · 1952
2 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Vest v. CommissionerUnited States Tax Court · 1971
- Popa v. CommissionerUnited States Tax Court · 1979
- Herbert P. Weinmann v. United StatesCourt of Appeals for the Second Circuit · 1960
- Folkman v. United StatesDistrict Court, D. Nevada · 1977
- Perlman v. CommissionerUnited States Tax Court · 1957
8 more not listed; retrieve them via the Exa API.