[DOWNLOAD] "Chicago Title & Trust Co. v. United States." by United States Court of Appeals Seventh Circuit. ~ Book PDF Kindle ePub Free
eBook details
- Title: Chicago Title & Trust Co. v. United States.
- Author : United States Court of Appeals Seventh Circuit.
- Release Date : January 02, 1954
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 61 KB
Description
Plaintiffs sued in the District Court to recover alleged over-payments of income taxes in the years 1943 and 1946 by the taxpayer for whose estate they are executors. They contended that the decedent, having experienced substantial losses in the sale of certain real estate owned by him in the years 1944 and 1945, should have been allowed to carry them back to the years 1942 and 1943 and forward to the year 1946, as deductions in computing his income taxes for those years, for the reason, as they asserted, that the losses were net operating losses attributable to the operation of a trade or business regularly carried on within the meaning of Section 122 (d)(5) of the Internal Revenue Code, 26 U.S.C. 1946 ed., Sections 23, 117 and 122. The decision of the District Court, 111 F.Supp. 314, turned upon its finding and conclusion that the losses in question were not attributable to the operation of a business by the taxpayer and, therefore, could not be treated as net operating deductions under Section 122. Accordingly the court entered judgment for defendant from which plaintiffs appeal.