Carpenter v. Commissioner
United States Board of Tax Appeals
Where the petitioner sold his interest in a partnership in order to avoid further personal losses, taking the notes of the surviving partners therefor, secured by the assignment of their partnership interests, and he claimed a deduction in the year of such sale upon the disposition of his partnership interest, which deduction was allowed, the further loss sustained in the following taxable period by reason of such notes becoming worthless is not a "net loss" within the…
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Where the petitioner sold his interest in a partnership in order to avoid further personal losses, taking the notes of the surviving partners therefor, secured by the assignment of their partnership interests, and he claimed a deduction in the year of such sale upon the disposition of his partnership interest, which deduction was allowed, the further loss sustained in the following taxable period by reason of such notes becoming worthless is not a "net loss" within the meaning of section 117(a) of the Revenue Act of 1928, since it is "not attributable to the operation of a trade or business…
1Opinion of the Court
LEWIS G. CARPENTER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Carpenter v. Commissioner
Docket No. 71617.
United States Board of Tax Appeals
33 B.T.A. 1; 1935 BTA LEXIS 820;
September 5, 1935, Promulgated
Where the petitioner sold his interest in a partnership in order to avoid further personal losses, taking the notes of the surviving partners therefor, secured by the assignment of their partnership interests, and he claimed a deduction in the year of such sale upon the disposition of his partnership interest, which deduction was allowed, the further loss sustained in the…
2Cases cited1 opinion
- Carpenter v. CommissionerUnited States Board of Tax Appeals · 1935