Legal Opinion

Harrington v. Commissioner

United States Board of Tax Appeals

Decided October 3, 1924No. Docket No. 11Published

A taxpayer regularly employed on a salary, who made five purchases of securities during 1921 from brokers and one sale of securities at a loss which exceeded his income for 1921, is not entitled to a deduction in his return for 1922 on account thereof under the provisions of section 204 of the Revenue Act of 1921, such loss not resulting from the operation of a business regularly carried on by the taxpayer.

1Opinion of the Court

Appeal of J. J. HARRINGTON.

Harrington v. Commissioner

Docket No. 11.

United States Board of Tax Appeals

1 B.T.A. 11; 1924 BTA LEXIS 280;

October 3, 1924, decided Submitted September 12, 1924.

A taxpayer regularly employed on a salary, who made five purchases of securities during 1921 from brokers and one sale of securities at a loss which exceeded his income for 1921, is not entitled to a deduction in his return for 1922 on account thereof under the provisions of section 204 of the Revenue Act of 1921, such loss not resulting from the operation of a business regularly carried on by the taxpayer.

No…

2Cases cited3 opinions

  1. Mente v. EisnerCourt of Appeals for the Second Circuit · 1920
  2. Woods v. LewellynDistrict Court, W.D. Pennsylvania · 1921
  3. Harrington v. CommissionerUnited States Board of Tax Appeals · 1924

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