PATTERSON v. COMMISSIONER OF INTERNAL REVENUE

No. 61.

42 F.2d 148 (1930)

PATTERSON v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

May 12, 1930.


Attorney(s) appearing for the Case

Robert H. Montgomery, of New York City (Thomas G. Haight, of Jersey City, N. J., J. Marvin Haynes, of Washington, D. C., and Roswell Magill, of Chicago, Ill., of counsel), for petitioner.

G. A. Youngquist, Asst. Atty. Gen., and Sewall Key and Andrew D. Sharpe, Sp. Assts. to Atty. Gen. (C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Dean P. Kimball, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for respondent.

Before L. HAND, CHASE, and MACK, Circuit Judges.


PER CURIAM.

The single question raised by the petition is the disallowance of a deficiency claimed by Patterson, the petitioner, arising from the sale of stock. In 1919 he sold for $1 two thousand shares of common stock in the International Mail Equipment Company, the shares being conceded at that time to be worthless. These he acquired in March, 1911, and asserts that at that time and two years later they had a value of ...

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