Seed v. Commissioner
United States Tax Court
As a participant in a joint venture to incorporate a savings and loan association, petitioners expended funds to secure a charter from the savings and loan commissioner of the State of California. The application for a charter was denied and the venture then abandoned. Held, petitioners' loss is deductible under sec. 165(c)(2) as a loss incurred in a transaction entered into for profit. Charles T. Parker, 1 T.C. 709 (1943).
1Opinion of the Court
OPINION
Sterrett, Jvdge:
The facts have been fully stipulated by the parties; accordingly the proceeding was submitted under Rule 30 of the Court’s Rules of Practice. The stipulated facts and the exhibits attached thereto are incorporated 'herein by this reference and are adopted as our findings of fact. A summary of the pertinent facts is set forth below.
The respondent determined a deficiency in the petitioners’ income tax for the calendar year 1964 of $3,385.29. The petitioners concede that their tax liability for 1964 was understated by $2,547.08 due to a mathematical error. The amount…
2Cases cited6 opinions
- Mercantile Nat. Bank at Dallas v. LangdeauSupreme Court of the United States · 1963
- Eli D. Goodstein v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Eli D. GoodsteinCourt of Appeals for the First Circuit · 1959
- Frank v. CommissionerUnited States Tax Court · 1953
- Goodstein v. CommissionerUnited States Tax Court · 1958
- Jefferson v. CommissionerUnited States Tax Court · 1968
1 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- O'Donnell v. CommissionerUnited States Tax Court · 1974
- Estate of Boyd v. CommissionerUnited States Tax Court · 1981
- Robert C. Honodel and Claire E. Honodel v. Commissioner of the Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Gawler v. CommissionerUnited States Tax Court · 1973
- Larsen v. CommissionerUnited States Tax Court · 1976
24 more not listed; retrieve them via the Exa API.