Whipple v. Commissioner

How courts have described this case

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

• holding that investing one's money and managing one's investments do not amount to a trade or business
• stating that someone in a trade or business gets \income received directly for his own services rather than indirectly through the corporate enterprise\
• interpreting “trade or business” in § 122(d)(5) of 1939 Code (§ 172 of 1954 Code)
• “Devoting one’s time and energies to the affairs of a corporation is not of itself, and without more, a trade or business of the person so engaged.”
• “investing is not trade or business” for purposes of deducting business bad debt
• “[I]nvesting is not a trade or business and the return to the taxpayer, though substantially the product of his services, legally arises not from his own trade or business but from that of the corporation.”

Source: CourtListener parenthetical corpus (CC0).