Legal Opinion

Steinback v. Commissioner

United States Board of Tax Appeals

Decided July 20, 1934No. Docket No. 61944Published

Deduction - Loss on Worthless Stock. - Respondent disallowed a claimed loss deduction for 1929 upon a finding that petitioner's stock became worthless in 1928, the year in which the corporation was adjudged insolvent.

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Deduction - Loss on Worthless Stock. - Respondent disallowed a claimed loss deduction for 1929 upon a finding that petitioner's stock became worthless in 1928, the year in which the corporation was adjudged insolvent. Petitioner failed to prove that the stock was not worthless in 1928. Held, the fact that until 1929 petitioner entertained hopes of effecting a reorganization and made unsuccessful efforts to bring those hopes into being, is not a sufficient basis upon which to conclude that the stock was not worthless in 1928 and became worthless when such hopes were abandoned in 1929.

1Opinion of the Court

WILLIAM E. STEINBACK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Steinback v. Commissioner

Docket No. 61944.

United States Board of Tax Appeals

30 B.T.A. 1252; 1934 BTA LEXIS 1205;

July 20, 1934, Promulgated

Deduction - Loss on Worthless Stock. - Respondent disallowed a claimed loss deduction for 1929 upon a finding that petitioner's stock became worthless in 1928, the year in which the corporation was adjudged insolvent. Petitioner failed to prove that the stock was not worthless in 1928. Held, the fact that until 1929 petitioner entertained hopes of effecting a reorganization…

2Cases cited1 opinion

  1. Steinback v. CommissionerUnited States Board of Tax Appeals · 1934

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