Crawford v. Commissioner
United States Board of Tax Appeals
39 B.T.A. 521 (1939)
- Written by Eric Miller, JD
Facts
George Crawford had a one-fourth ownership interest in Venempa Investment Co., a partnership. The Venempa Investment partners agreed to dissolve the partnership. Upon dissolution, assets were distributed among the partners, mostly in the form of investments in securities, rather than cash. Crawford’s income-tax return for 1932 included no deduction of partnership losses sustained in the liquidation. After Crawford’s death, the executors of his estate (the estate) (plaintiff) asserted a claim that Crawford had in fact sustained a loss in the liquidation—i.e., that the cost of Crawford’s partnership interest exceeded the market value of the assets distributed to him—resulting in an overpayment of taxes. The case came before the United States Board of Tax Appeals.
Rule of Law
Issue
Holding and Reasoning (Hill, J.)
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