Davenport v. Commissioner
United States Tax Court
Greenbelt derived more than 50 percent of its gross receipts from interest. Held: Greenbelt was not largely an operating company. Its stock is therefore not sec. 1244, I.R.C. 1954, stock, and losses thereon are not sec. 1244, I.R.C. 1954, losses. Sec. 1.1244(c)-1(g)(2), Income Tax Regs., followed. Petitioner's purchases of Greenbelt stock and loans to Greenbelt were motivated by investment reasons.
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Greenbelt derived more than 50 percent of its gross receipts from interest. Held: Greenbelt was not largely an operating company. Its stock is therefore not sec. 1244, I.R.C. 1954, stock, and losses thereon are not sec. 1244, I.R.C. 1954, losses. Sec. 1.1244(c)-1(g)(2), Income Tax Regs., followed. Petitioner's purchases of Greenbelt stock and loans to Greenbelt were motivated by investment reasons. Held, petitioners were not entitled to ordinary loss treatment when the stock and loans became worthless.
1Opinion of the Court
H. L. Davenport and Neysa C. Davenport, Petitioners v. Commissioner of Internal Revenue, Respondent
Davenport v. Commissioner
Docket No. 5317-76
United States Tax Court
70 T.C. 922; 1978 U.S. Tax Ct. LEXIS 57;
September 14, 1978, Filed
Decision will be entered under Rule 155.
Greenbelt derived more than 50 percent of its gross receipts from interest. Held: Greenbelt was not largely an operating company. Its stock is therefore not sec. 1244, I.R.C. 1954, stock, and losses thereon are not sec. 1244, I.R.C. 1954, losses. Sec. 1.1244(c)-1(g)(2), Income Tax Regs., followed. Petitioner's purchases of…
Also in this document: Concurrence; Dissent.
2Cases cited21 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- 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
- United States v. GeneresSupreme Court of the United States · 1972
- Booth Newspapers, Inc. v. The United States. The Evening News Association v. The United StatesUnited States Court of Claims · 1962
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