# United States Trust Co. v. Commissioner

> United States Board of Tax Appeals · March 25, 1925 · 1 B.T.A. 901

URL: https://www.frixlaw.com/law-library/cases/4487502

## Case

- **Full name:** Appeal of UNITED STATES TRUST CO.
- **Court:** United States Board of Tax Appeals
- **Decided:** March 25, 1925
- **Citations:** 1 B.T.A. 901; 1925 BTA LEXIS 2771
- **Precedential status:** Published
- **Opinion:** Opinion of the court by Graupner
- **Judges:** Lansdon, Graupner, Smith, Littleton
- **Cited by:** 0 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4487502

## Opinion text

*903 OPINION.
Graupner :
The taxpayer contends that the situation presented for our consideration is a simple one, consisting only of a purchase of *904 shares of stock for cash, the receipt of a less amount upon surrender of the stock, and a consequent deductible loss. The transaction thus presented is so simple that it is confounding.
Before March 30, 1918, the taxpayer owned directly, or controlled, all of the stock of the Company, and, therefore, the Company was an affiliated subsidiary of the taxpayer. The liquidation of the Company did not in any way produce a loss which the taxpayer would be allowed to deduct under section 234 (a) of the Revenue Act of 1918.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4487502. Public record. Not legal advice.