Egly v. Commissioner
United States Tax Court
Stock owned by P became worthless during the year, but P kept few, if any, records with respect to capital contributions to corporations controlled by her. On the basis of testimony and checks in evidence, Held: P has established her entitlement to a loss on worthless stock. Held further: P's basis determined by making an approximation thereof. P also reported NOL and ITC carryforwards on her tax return, much of which were not usable because P's reported income was zero.
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Stock owned by P became worthless during the year, but P kept few, if any, records with respect to capital contributions to corporations controlled by her. On the basis of testimony and checks in evidence, Held: P has established her entitlement to a loss on worthless stock. Held further: P's basis determined by making an approximation thereof. P also reported NOL and ITC carryforwards on her tax return, much of which were not usable because P's reported income was zero. The notice of deficiency disallowed a large deduction for worthless stock, but did not mention specifically that the NOLs…
1Opinion of the Court
MARTHA H. EGLY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Egly v. Commissioner
Docket No. 29753-85.
United States Tax Court
T.C. Memo 1988-223; 1988 Tax Ct. Memo LEXIS 251; 55 T.C.M. (CCH) 877; T.C.M. (RIA) 88223;
May 18, 1988
Stock owned by P became worthless during the year, but P kept few, if any, records with respect to capital contributions to corporations controlled by her. On the basis of testimony and checks in evidence, Held: P has established her entitlement to a loss on worthless stock. Held further: P's basis determined by making an approximation thereof.
P also reported…
2Cases cited40 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Burnet v. HoustonSupreme Court of the United States · 1931
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
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