Legal Opinion

Rogers v. Commissioner

United States Tax Court

Decided October 24, 1961No. Docket Nos. 84596, 84597Unpublished

Petitioner, a member of the Kentucky bar, owned and operated a variety store. In 1953 the lessor of the store's premises canceled the lease and petitioner ceased to operate the store. The fixtures were sold and its merchandise inventory placed in storage. Petitioner attempted to sell the merchandise in bulk and finally did so in 1958. For the years 1955, 1956 and 1957 petitioner reported losses resulting from the estimated decrease in value of the inventory while in storage.

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Petitioner, a member of the Kentucky bar, owned and operated a variety store. In 1953 the lessor of the store's premises canceled the lease and petitioner ceased to operate the store. The fixtures were sold and its merchandise inventory placed in storage. Petitioner attempted to sell the merchandise in bulk and finally did so in 1958. For the years 1955, 1956 and 1957 petitioner reported losses resulting from the estimated decrease in value of the inventory while in storage. Respondent disallowed the losses. Held, the losses claimed were correctly disallowed. Held, further, expenditures for…

1Opinion of the Court

Wesley J. Rogers v. Commissioner. Estate of Dorothy H. Rogers, Deceased, Wesley J. Rogers, Administrator, and Wesley J. Rogers, individually v. Commissioner.

Rogers v. Commissioner

Docket Nos. 84596, 84597.

United States Tax Court

T.C. Memo 1961-291; 1961 Tax Ct. Memo LEXIS 56; 20 T.C.M. (CCH) 1515; T.C.M. (RIA) 61291;

October 24, 1961

Petitioner, a member of the Kentucky bar, owned and operated a variety store. In 1953 the lessor of the store's premises canceled the lease and petitioner ceased to operate the store. The fixtures were sold and its merchandise inventory placed in storage. Petitioner…

2Cases cited3 opinions

  1. Owen v. CommissionerUnited States Tax Court · 1954
  2. C-O-Two Fire Equipment Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1955
  3. Dunn Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1928

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