Legal Opinion

Young v. Commissioner

United States Board of Tax Appeals

Decided June 2, 1936No. Docket No. 78345Published

1. The taxpayer's exercise of an unqualified right to surrender shares in a security-holding organization and receive an aliquot portion of its assets, a composite fund, resulted in a deductible loss, it appearing that the taxpayer's ownership of an interest in the fund was different from the ownership by the organization in the fund itself. 2. A loss on the sale of shares through a broker, held, deductible although an equal number of the same shares was simultaneously…

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1. The taxpayer's exercise of an unqualified right to surrender shares in a security-holding organization and receive an aliquot portion of its assets, a composite fund, resulted in a deductible loss, it appearing that the taxpayer's ownership of an interest in the fund was different from the ownership by the organization in the fund itself. 2. A loss on the sale of shares through a broker, held, deductible although an equal number of the same shares was simultaneously purchased by a business associate of the taxpayer and by him transferred to the taxpayer's wife, who paid for them with her…

1Opinion of the Court

DU BOIS YOUNG, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Young v. Commissioner

Docket No. 78345.

United States Board of Tax Appeals

34 B.T.A. 648; 1936 BTA LEXIS 669;

June 2, 1936, Promulgated

1. The taxpayer's exercise of an unqualified right to surrender shares in a security-holding organization and receive an aliquot portion of its assets, a composite fund, resulted in a deductible loss, it appearing that the taxpayer's ownership of an interest in the fund was different from the ownership by the organization in the fund itself.

2. A loss on the sale of shares through a broker,…

2Cases cited13 opinions

  1. Fouke v. CommissionerUnited States Board of Tax Appeals · 1925
  2. Robertson v. CommissionerUnited States Board of Tax Appeals · 1930
  3. Uihlein v. CommissionerUnited States Board of Tax Appeals · 1934
  4. Blumenthal v. CommissionerUnited States Board of Tax Appeals · 1934
  5. Brochon v. CommissionerUnited States Board of Tax Appeals · 1934

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