Makransky's Estate v. COMMISSIONER OF INTERNAL REVENUE

Third Circuit

Makransky's Estate v. COMMISSIONER OF INTERNAL REVENUE

154 F.2d 59

CourtCourt of Appeals for the Third Circuit

DecidedFebruary 25, 1946

Docket9076-9080

StatusPublished

Cited by2 cases

This text of 154 F.2d 59 (Makransky's Estate v. COMMISSIONER OF INTERNAL REVENUE) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Makransky's Estate v. COMMISSIONER OF INTERNAL REVENUE, 154 F.2d 59 (3d Cir. 1946).

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Opinion

PER CURIAM.

In these cases the taxpayers ask this court to review the finding of the Tax Court that a loss which they incurred in the sale of contracts for the future delivery of wool was a loss upon the sale of capital assets and not an ordinary and necessary expense of their business deductible under Section 23(a) of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code, § 23(a), or a loss deductible under Section 23(e). We think that this is a finding which this court is not at liberty to review. Dobson v. Commissioner, 1943, 320 U.S. 489, 64 S.Ct. 239, 88 L.Ed. 248; John Kelley Co. v. Commissioner, 1946, 66 S.Ct. 299.

The decision of the Tax Court is affirmed.

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PER CURIAM.

In these cases the taxpayers ask this court to review the finding of the Tax Court that a loss which they incurred in the sale of contracts for the future delivery of wool was a loss upon the sale of capital assets and not an ordinary and necessary expense of their business deductible under Section 23(a) of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code, § 23(a), or a loss deductible under Section 23(e). We think that this is a finding which this court is not at liberty to review. Dobson v. Commissioner, 1943, 320 U.S. 489, 64 S.Ct. 239, 88 L.Ed. 248; John Kelley Co. v. Commissioner, 1946, 66 S.Ct. 299.

The decision of the Tax Court is affirmed.

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154 F.2d 59, Counsel Stack Legal Research, https://law.counselstack.com/opinion/makranskys-estate-v-commissioner-of-internal-revenue-ca3-1946.

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