John C. Echols and Deanna O. Echols v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• noting that taking loss deduction on tax return is manifestation of taxpayer’s intent that partnership interest was worthless
• “[P]roperty cannot be treated as worthless for tax loss purposes if at the time it, objectively, has substantial value.”
• “[T]he abandoning party must manifest an intent to abandon by some overt act or statement reasonably calculated to give a third party notice of the abandonment.”
• “[T]he more important question of when a property is worthless for purposes of a loss deduction under * * * [section] 165(a) is, like beauty, largely in the eyes (more accurately, the mind) of the beholder (more accurately, the holder).”
• noting the Court did not address the issue of worthlessness

Source: CourtListener parenthetical corpus (CC0).