Newton v. Commissioner
United States Tax Court
Held: 1. Petitioners are not entitled to any net operating loss deduction in 1968 for a loss incurred in 1963 on the sale of the goodwill of an insurance agency and a loss in 1964 resulting from a mortgage foreclosure sale of their personal residence. 2. Petitioners are not entitled to a casualty loss deduction under sec. 165(c)(3), I.R.C. 1954, when the motor of an 11-year-old automobile "burned out" while being driven on a highway. 3. Amount of automobile business expenses…
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Held: 1. Petitioners are not entitled to any net operating loss deduction in 1968 for a loss incurred in 1963 on the sale of the goodwill of an insurance agency and a loss in 1964 resulting from a mortgage foreclosure sale of their personal residence. 2. Petitioners are not entitled to a casualty loss deduction under sec. 165(c)(3), I.R.C. 1954, when the motor of an 11-year-old automobile "burned out" while being driven on a highway. 3. Amount of automobile business expenses determined.
1Opinion of the Court
Dawson, Judge:
Respondent determined a deficiency of $715.59 in petitioners’ Federal income tax for the year 1968.
Three questions are presented for onr decision:(1) Are petitioners entitled to a net operating loss deduction for the year 1968 ?(2) Are petitioners entitled to a casualty loss deduction in 1968 with respect to their damaged automobile?(3) Are petitioners entitled to a deduction for business use of an automobile in excess of the amount allowed by respondent?
FINDINGS OP PACT
Some of the facts have been stipulated and are found accordingly.
Ellery Willis Newton and Helen Morehouse1…
2Cases cited9 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Fay v. HelveringCourt of Appeals for the Second Circuit · 1941
- Leslie v. CommissionerUnited States Tax Court · 1946
- United States v. RogersCourt of Appeals for the Ninth Circuit · 1941
- Peter Seletos v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1958
4 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Lone Manor Farms, Inc. v. CommissionerUnited States Tax Court · 1974
- Nisselson v. Drew Industries, Inc. (In Re White Metal Rolling & Stamping Corp.)United States Bankruptcy Court, S.D. New York · 1998
- Glenn Ross Smith v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1979
- Prewitt v. CommissionerUnited States Tax Court · 1995
- Batson v. CommissionerUnited States Tax Court · 1982
11 more not listed; retrieve them via the Exa API.