White Star Line v. Commissioner
United States Board of Tax Appeals
1. Mere diminution of actual value of property owned does not result in a sustained loss even if the diminution occur in the taxable year. 2. Because of economic changes, a taxpayer decided at the end of 1924 to discontinue operations and sell its property. The property remained in taxpayer's ownership and possession throughout and was neither abandoned nor discarded during 1924, and was in fact sold in 1925. There was no evidence of complete or partial worthlessness.
Read the full summary
1. Mere diminution of actual value of property owned does not result in a sustained loss even if the diminution occur in the taxable year. 2. Because of economic changes, a taxpayer decided at the end of 1924 to discontinue operations and sell its property. The property remained in taxpayer's ownership and possession throughout and was neither abandoned nor discarded during 1924, and was in fact sold in 1925. There was no evidence of complete or partial worthlessness. The taxpayer claimed a deduction for loss of useful value of its property in 1924 on the ground that the value of its…
1Opinion of the Court
OPINION.
Steiinhagen:
The respondent, after audit of petitioner’s return for 1924, increased its net income from $6,344.28 to $16,448.28 by adding four items of income and applying two items of deductions. This resulted in the determination of a deficiency of $1,263.01. The petitioner attacks none of these adjustments, but seeks to overcome the deficiency by proving a new deduction not taken on its return or heretofore claimed.
The petitioner owned and operated five freight and passenger vessels on the Great Lakes. By reason of the increase of competí-*112five automobile traffic and the enactment of…
2Cited by11 opinions
- Proesel v. CommissionerUnited States Tax Court · 1981
- Beatty v. CommissionerUnited States Tax Court · 1966
- Olean Times-Herald Corp. v. CommissionerUnited States Board of Tax Appeals · 1938
- Adams v. CommissionerUnited States Tax Court · 1977
- Beatty v. CommissionerUnited States Tax Court · 1966
6 more not listed; retrieve them via the Exa API.