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Burnet v. Clark, 287 U.S. 410 (1932)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Burnet v. Clark, 287 U.S. 410 (1932)
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Burnet v. Clark No. 180 Argued November 14, 1932 Decided December 12, 1932 287 U.S. 410
CERTIORARI TO THE COURT OF APPEALS
OF THE DISTRICT OF COLUMBIA
Syllabus
The taxpayer was interested in a corporation engaged in river and harbor improvement work, as majority stockholder and president, and devoted himself largely to its affairs. He was also interested in other concerns engaged in similar work, and had investments in other corporate shares. He treated the corporation as a separate entity for taxation, and made separate personal income tax returns. Through endorsement of obligations of the corporation, and sale of its stock, he suffered net losses in 1921 and 1922, for which he claimed deductions in his return for 1923. He was not in the business of endorsing or buying and selling securities.
Held:
The losses did not result "from the operation of any trade or business regularly carried on by the taxpayer," and, under the Revenue Act of 1921, § 204, were not deductible from gains of succeeding years. P. 414.
61 App.D.C. 217, 59 F.2d 1031, reversed.
Certiorari to review a judgment reversing a decision of the Board of Tax Appeals, 19 B.T.A. 859, which sustained an order of the Commissioner determining a deficiency in income tax. Cf. the cases next preceding and following.
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Chicago: U.S. Supreme Court, "Syllabus," Burnet v. Clark, 287 U.S. 410 (1932) in 287 U.S. 410 287 U.S. 411. Original Sources, accessed November 22, 2024, http://originalsources.com/Document.aspx?DocID=12F6Q66HQLU51I7.
MLA: U.S. Supreme Court. "Syllabus." Burnet v. Clark, 287 U.S. 410 (1932), in 287 U.S. 410, page 287 U.S. 411. Original Sources. 22 Nov. 2024. http://originalsources.com/Document.aspx?DocID=12F6Q66HQLU51I7.
Harvard: U.S. Supreme Court, 'Syllabus' in Burnet v. Clark, 287 U.S. 410 (1932). cited in 1932, 287 U.S. 410, pp.287 U.S. 411. Original Sources, retrieved 22 November 2024, from http://originalsources.com/Document.aspx?DocID=12F6Q66HQLU51I7.
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