Howell v. Commissioner
United States Tax Court
Partnership loss claimed by petitioner held, on the facts, not to have been incurred in a business or transaction entered into for profit and hence not deductible under section 165, I.R.C. 1954.
1Opinion of the Court
Valentine Howell and Loretta B. Howell, Petitioners, v. Commissioner of Internal Revenue, Respondent
Howell v. Commissioner
Docket No. 86581
United States Tax Court
41 T.C. 13; 1963 U.S. Tax Ct. LEXIS 41;
October 4, 1963, Filed
Decision will be entered for the respondent.
Partnership loss claimed by petitioner held, on the facts, not to have been incurred in a business or transaction entered into for profit and hence not deductible under section 165, I.R.C. 1954.
Carl F. Bauersfeld, for the petitioners.
Henry G. Nagel, for the respondent.
Opper, Judge.
OPPER
Respondent has determined a deficiency in…
2Cases cited5 opinions
- Henry P. White and Estate of Nancy A. White, Deceased, T. Leo Sullivan, Administrator, C.T.A. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1955
- Morton v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
- Ewing v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
- George T. McLean and Amelia G. McLean v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1961
- Howell v. CommissionerUnited States Tax Court · 1963