holding that the worthlessness of an equity interest depends “not only on its current liquidating value, but also on what value it may acquire in the future through the foreseeable operations of the * * * [company]”
How later courts described this case
- holding that the worthlessness of an equity interest depends “not only on its current liquidating value, but also on what value it may acquire in the future through the foreseeable operations of the * * * [company]”
- noting that identifiable events are “called ‘identifiable’ in that they are likely to be immediately known by everyone having -47- [ ] an interest by way of stockholdings or otherwise in the affairs of the corporation”
- taxpayer must demonstrate a “reasonable hope and expectation that the assets will exceed the liabilities of the corporation in the future”
- worthlessness of stock depends on current liquidating value and potential value
Written by the judges who cited it.
The opinion
Black,
dissenting: I dissent from the views expressed in the majority opinion as to issue No. 3. I think'the facts show that petitioner has proved his loss of investment in the 1242 Lake Shore. Drive Syndicate to all reasonable extent and purpose and should be allowed this loss in a computation of his net income for 1932. That he will ever recover anything from this investment seems to me so remote and improbable that it should not be the basis of disallowing the loss which petitioner claims.