# Joe Siegel, Inc. v. Commissioner

> United States Board of Tax Appeals · May 6, 1925 · 1 B.T.A. 1113

URL: https://www.frixlaw.com/law-library/cases/4604801

## Case

- **Full name:** Appeal of JOE SIEGEL, INC.
- **Court:** United States Board of Tax Appeals
- **Decided:** May 6, 1925
- **Citations:** 1 B.T.A. 1113; 1925 BTA LEXIS 2659
- **Precedential status:** Published
- **Opinion:** Opinion
- **Judges:** Lansdon, Graupner, Gkeen
- **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/4604801

## Opinion text

Appeal of JOE SIEGEL, INC.
Joe Siegel, Inc. v. Commissioner
Docket No 1739.
United States Board of Tax Appeals
1 B.T.A. 1113 ; 1925 BTA LEXIS 2659 ;
May 6, 1925 , decided Submitted April 1, 1925 .
*2659 Harry Friedman, Esq., for the taxpayer.
A. Calder Mackay, Esq., for the Commissioner.
*1113 Before GRAUPNER, LANSDON, and GREEN.
This is an appeal from a determination of a deficiency in income tax for the calendar year 1922. The appeal presents in substance the same question passed upon by this Board in the appeals of the , and the . From the allegations of the petition which were admitted by the answer of the Commissioner, we make the following
FINDINGS OF FACT.
The taxpayer is a New York corporation. On December 11, 1924, the taxpayer received the usual deficiency letter asserting a deficiency in the sum of $479.66. This corporation was organized early in the year 1921, having filed its certificate of incorporation on January 3 of that year and having received its authorization to do business on the 7th day of January. The corporation sustained a net loss of $5,344.97 in 1921, and so reported in its income-tax return. In its income-tax return for 1922 it set up the net loss for the year 1921 as a deduction, and after taking such deduction showed *2660 a net income of $492.32. The Commissioner disallowed the net-loss deduction upon the theory that the taxpayer had not had a full taxable year 1921.
DECISION.
The deficiency determined by the Commissioner is disallowed.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4604801. Public record. Not legal advice.