Ernest W. Brown, Inc. v. Commissioner
United States Tax Court
1. Deduction -- Loss -- Termination of Contracts and Business. -- The taxpayer has not shown its right to deduct in 1952 an alleged loss on contracts which, by their terms, could not survive the death in 1947 of the one man who was to perform the work under those contracts. 2. Id. -- Basis -- Transferee Takes Transferor's Zero Basis -- Secs. 112 (b) (5) and 113 (a) (8) and (b). -- The transaction in 1923 whereby the petitioner was named attorney in fact and manager and…
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1. Deduction -- Loss -- Termination of Contracts and Business. -- The taxpayer has not shown its right to deduct in 1952 an alleged loss on contracts which, by their terms, could not survive the death in 1947 of the one man who was to perform the work under those contracts. 2. Id. -- Basis -- Transferee Takes Transferor's Zero Basis -- Secs. 112 (b) (5) and 113 (a) (8) and (b). -- The transaction in 1923 whereby the petitioner was named attorney in fact and manager and thereby succeeded to a profitable business formerly conducted individually by its sole stockholder was within sections 112…
1Opinion of the Court
Ernest W. Brown, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Ernest W. Brown, Inc. v. Commissioner
Docket No. 58017
United States Tax Court
28 T.C. 682; 1957 U.S. Tax Ct. LEXIS 156;
June 21, 1957, Filed
Decision will be entered for the respondent.
1. Deduction -- Loss -- Termination of Contracts and Business. -- The taxpayer has not shown its right to deduct in 1952 an alleged loss on contracts which, by their terms, could not survive the death in 1947 of the one man who was to perform the work under those contracts.
2. Id. -- Basis -- Transferee Takes Transferor's Zero Basis --…
2Cases cited1 opinion
- Ernest W. Brown, Inc. v. CommissionerUnited States Tax Court · 1957