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In 1939 the taxpayers paid $15,000 to Edwards Development Corporation which they caused to be organized under the laws of Illinois with an authorized capital of 100 shares without par value. The directors of the corporation set the value of the stock at $10 per share and directed its sale at that figure. The corporate enterprise proved a failure and in 1940 the corporation was dissolved, only a small part of their $15,000 payment being returned to the taxpayers. It is their contention that their payment should be segregated into two parts, $1,000 thereof being allocated as a capital investment in the stock and $14,000 as a loan, and that they are entitled respectively to bad debt deductions of $3,546.86 and $7,093.72. The commissioner, however, determined that their losses were short term capital losses and that the allowable deduction was subject to the limitations of section 117(d) of the Internal Revenue Code as amended by section 212 of the Revenue Act of 1939, 53 Stat. 869, 26 U.S.C.A. Int.Rev.Code, 117(d). The Tax Court approved the commissioner's determination.
One of the key differences to previous property booms was the general uniformity of price growth across most parts of the country. Whilst houses noticeably outperformed units in most markets, it was rare to find a location that didn't see strong performance at a headline level. 2ff7e9595c
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