W. W. Windle Co. v. Commissioner
United States Tax Court
Petitioner, a wool processor, created Nor-West and acquired 72 percent of its stock, to manufacture woolen cloth. Petitioner's predominant motive for creating Nor-West was to have a captive customer for its processed wool. A secondary motive was to make a profitable investment. Petitioner subsequently made repeated loans and advances to Nor-West, which after 9 generally unsuccessful years went bankrupt.
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Petitioner, a wool processor, created Nor-West and acquired 72 percent of its stock, to manufacture woolen cloth. Petitioner's predominant motive for creating Nor-West was to have a captive customer for its processed wool. A secondary motive was to make a profitable investment. Petitioner subsequently made repeated loans and advances to Nor-West, which after 9 generally unsuccessful years went bankrupt. Held: On the facts, petitioner's stock in Nor-West was a capital asset in its hands and petitioner's losses therefrom were capital losses. The existence of a substantial investment motive…
1Opinion of the Court
W. W. Windle Company, Petitioner v. Commissioner of Internal Revenue, Respondent
W. W. Windle Co. v. Commissioner
Docket No. 9426-72
United States Tax Court
65 T.C. 694; 1976 U.S. Tax Ct. LEXIS 179;
January 7, 1976, Filed
Decision will be entered under Rule 155.
Petitioner, a wool processor, created Nor-West and acquired 72 percent of its stock, to manufacture woolen cloth. Petitioner's predominant motive for creating Nor-West was to have a captive customer for its processed wool. A secondary motive was to make a profitable investment. Petitioner subsequently made repeated loans and advances to…
2Cases cited27 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Malat v. RiddellSupreme Court of the United States · 1966
- Hort v. CommissionerSupreme Court of the United States · 1941
- United States v. GeneresSupreme Court of the United States · 1972
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