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STROUSE v. COMMISSIONER OF INTERNAL REVENUE

No. 3278.

59 F.2d 600 (1932)

STROUSE v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fourth Circuit.

June 13, 1932.

Attorney(s) appearing for the Case

Malcolm H. Lauchheimer, of Baltimore, Md. (Sylvan Hayes Lauchheimer, of Baltimore, Md., on the brief), for petitioner.

John H. McEvers, Sp. Asst. to Atty. Gen. (G. A. Youngquist, Asst. Atty. Gen., Sewall Key and Carlton Fox, Sp. Assts. to Atty. Gen., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and R. W. Wilson, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief), for respondent.

Before PARKER, and SOPER, Circuit Judges, and WAY, District Judge.

SOPER, Circuit Judge.

Eli Strouse, the petitioner in this case, is endeavoring to take advantage of those provisions of the Revenue Acts whereby a net loss for any taxable year, resulting from the operation of a trade or business regularly carried on by a taxpayer, is allowed as a deduction in computing the net income of the taxpayer for the succeeding taxable year. See Revenue Act of 1921, § 204(a), 42 Stat. 227, 231; Revenue Act of 1924, § 206(b), (f)...

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