Pollack v. Commissioner
United States Tax Court
Petitioner, a management consultant, purchased an interest in Millworth, a limited partnership, to secure a new source of potential consulting business. When the anticipated consulting business failed to materialize, petitioner disposed of his interest at a loss. Held, sec. 741, I.R.C. 1954, is dispositive of the character of petitioner's loss; petitioner therefore sustained a capital loss on the disposition of his partnership interest.
1Opinion of the Court
Fay, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax as follows:
Year Deficiency
1966.$2,545.03
1969.1,433.98
The deficiency for 1966 resulted from a disallowance by respondent of a claimed net operating loss carryback from 1969. We are to decide whether petitioner H. Clinton Pollack, Jr., is entitled to an ordinary loss treatment on the disposition of his interest in a limited partnership during 1969.
FINDINGS OF FACT
Certain facts have been stipulated by the parties.
Petitioners H. Clinton Pollack, Jr., and Wendy Pollack are husband and wife who resided in Greenwich,…
2Cases cited9 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Helvering v. William Flaccus Oak Leather Co.Supreme Court of the United States · 1941
- Swiren v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1950
- Lehman v. CommissionerUnited States Tax Court · 1946
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