Martin v. Commissioner
United States Tax Court
Petitioners incurred substantial losses in their sole proprietorship and, on May 14, 1965, filed a petition in bankruptcy. Held, in computing their net operating loss for 1965, petitioners must aggregate the income and expenses from all their business endeavors during the entire year and may not reduce their business income by their personal exemption and nonbusiness deductions.
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Petitioners incurred substantial losses in their sole proprietorship and, on May 14, 1965, filed a petition in bankruptcy. Held, in computing their net operating loss for 1965, petitioners must aggregate the income and expenses from all their business endeavors during the entire year and may not reduce their business income by their personal exemption and nonbusiness deductions. Sec. 172(d)(3) and (4), I.R.C. 1954. Held, further, in computing their net operating loss for 1965, petitioners may not deduct the cost of the inventory of merchandise which they turned over to the trustee in…
1Opinion of the Court
FeatheRSTON, Judge:
Respondent determined deficiencies in petitioners’ Federal income taxes for 1966 and 1967 in the amounts of $438.01 and $693.20, respectively. The sole issue for decision is whether in 1966 and 1967 petitioners are entitled to deductions under section 1721 for a net operating loss carryover from 1965 in excess of the amounts allowed by respondent.
FINDINGS OF FACT
Homer A. Martin, Jr. (hereinafter referred to as Homer), and Alma M. Martin (hereinafter Alma), husband and wife, were residents of Victoria, Tex., at the time they filed their petition. They filed joint Federal…
2Cases cited16 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Segal v. RochelleSupreme Court of the United States · 1966
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Martin v. CommissionerUnited States Tax Court · 1969
- Pottstown Iron Co. v. United StatesSupreme Court of the United States · 1931
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3Cited by21 opinions
- Estate of Delman v. CommissionerUnited States Tax Court · 1979
- Mueller v. CommissionerUnited States Tax Court · 1973
- Davis v. CommissionerUnited States Tax Court · 1978
- Todd v. CommissionerUnited States Tax Court · 1981
- Strong v. CommissionerUnited States Tax Court · 1988
16 more not listed; retrieve them via the Exa API.