...or dairy purposes, and held by him for 12 months or more from the date of acquisition. (2) GHNERAL RULE. — If, during the taxable year, the recognized...or exchanges of capital assets. For the purposes of lliis paragraph : (A) In determining under this paragraph whether gains exceed losses, the gains and...

...INVOLUNTARY CONVERSIONS. (a) GENERAL RULE. — If, during the taxable year, the recognized gains on after December 31, 1 purposes of this subsection — (1) in determining under this subsection whether gains exceed losses,...

...by the taxpayer primarily for sale to customers in the ordinary course of his trade or business .... "(2) General rule. "If, during the taxable year, the...or exchanges of capital assets held for more than 6 months. . . ." 130 Opinion of the Court. The Tax Court, adopting its opinion in Midwest Motor Express,...

...by the taxpayer primarily for sale to customers in the ordinary course of his trade or business .... "(2) General rule. "If, during the taxable year, the...or exchanges of capital assets held for more than 6 months. . . ." COMMISSIONER v. GILLETTE MOTOR CO. 133 130 Opinion of the Court. The Tax Court, adopting...

...INVOLUNTARY CONVERSIONS. (a) OENEBAL RULE. — If, during the taxable year, the recognized gains on sales or exchanges of property used In the trade or...or exchanges of capital assets held for more than 0 months. If such gains do not exceed such losses, such gains and losses shall not be considered as...

...General rule. "If, during the taxable year, the recognized gains upon sales or exchanges of property nsed in the trade or business, plus the recognized gains...or exchanges of capital assets held for more than 6 months . . ." within the capital-gains provisions of the Internal Revenue Code. Rather, it is necessary...

...year, the recognized gains upon sales or exchanges of property used In the trade or business * * * exceed the recognized losses from such sales, exchanges,...months. If such gains do not exceed such losses, such trains and losses shall not be considered as gains and losses from sales or exchanges of capital assets....

...to recover some or all of the taxes previously paid for those years. 572 Opinion of tha Court ceed the recognized losses from such sales, exchanges,...considered as gains and losses from sales or exchanges of capital assets. * * * Plaintiffs say that American sold its stock in the Detroit Edison Company...

...taxpayer primarily for sale to customers in the ordinary course of his trade or business, * * *. (j) (2) If, during the taxable year, the recognized gains...or exchanges of capital assets held for more than 6 months. * * * In order for the plaintiff to come within the provisions of section 117(j) the burden...

...provided in part as follows : (a) GENERAL RULE. — If, during the taxable year, the recognized gains on sales or exchanges of property used In the trade or...losses from sales or exchanges of capital assets. For purposes of this subsection — • •••••• (2) losses upon the destruction, In whole or...