Davis v. Commissioner
United States Tax Court
1. Petitioner carried on farming, livestock, and packing activities through the medium of four proprietorships in Mexico, Texas, Florida, and the Bahamas.
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1. Petitioner carried on farming, livestock, and packing activities through the medium of four proprietorships in Mexico, Texas, Florida, and the Bahamas. Held, two of the principal proprietorships constituted several and separate businesses and their losses cannot be aggregated in determining losses disallowable under section 130, I. R. C. 1939. 2. In 1949 petitioner and respondent agreed on deficiencies for the years 1944 and 1945 and signed Form 870-TS (Modified). In 1950, after the statute of limitations on assessment of deficiencies for 1944 and 1945 had run, petitioner filed refund…
1Opinion of the Court
Arthur V. Davis, Petitioner, v. Commissioner of Internal Revenue, Respondent
Davis v. Commissioner
Docket No. 57897
United States Tax Court
29 T.C. 878; 1958 U.S. Tax Ct. LEXIS 256;
February 18, 1958, Filed
Decision will be entered under Rule 50.
1. Petitioner carried on farming, livestock, and packing activities through the medium of four proprietorships in Mexico, Texas, Florida, and the Bahamas. Held, two of the principal proprietorships constituted several and separate businesses and their losses cannot be aggregated in determining losses disallowable under section 130, I. R. C. 1939.
2. In 1949…
Also in this document: Dissent.
2Cases cited19 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Stone v. WhiteSupreme Court of the United States · 1937
- Fairmont Aluminum Company v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1955
- Wehrman v. ConklinSupreme Court of the United States · 1894
- Joyce v. GentschCourt of Appeals for the Sixth Circuit · 1944
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