Legal Opinion

Haley v. Commissioner

United States Tax Court

Decided June 29, 1951No. Docket No. 28000Published

1. Deduction -- Operating Losses -- Cash Basis -- No Payments. -- A taxpayer using the cash receipts and disbursements basis has no right to deduct on his return an operating loss of a business, even though he managed that business, where an associate advanced all of the money lost in the unsuccessful operation of the business and the taxpayer gave his notes to his associate for one-half of the money advanced but never made any payment on the notes. 2. Gain or Loss --…

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1. Deduction -- Operating Losses -- Cash Basis -- No Payments. -- A taxpayer using the cash receipts and disbursements basis has no right to deduct on his return an operating loss of a business, even though he managed that business, where an associate advanced all of the money lost in the unsuccessful operation of the business and the taxpayer gave his notes to his associate for one-half of the money advanced but never made any payment on the notes. 2. Gain or Loss -- Exchange -- Property for Stock and Notes. -- The incorporation of a business did not result in any gain to the petitioner who…

1Opinion of the Court

D. G. Haley and Anne M. Haley, Petitioners, v. Commissioner of Internal Revenue, Respondent

Haley v. Commissioner

Docket No. 28000

United States Tax Court

16 T.C. 1509; 1951 U.S. Tax Ct. LEXIS 147;

June 29, 1951, Promulgated

Decision will be entered under Rule 50.

1. Deduction -- Operating Losses -- Cash Basis -- No Payments. -- A taxpayer using the cash receipts and disbursements basis has no right to deduct on his return an operating loss of a business, even though he managed that business, where an associate advanced all of the money lost in the unsuccessful operation of the business and the…

2Cases cited1 opinion

  1. Haley v. CommissionerUnited States Tax Court · 1951

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