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BURNET v. COMMONWEALTH IMP. CO.

No. 95.

287 U.S. 415 (1932)

BURNET, COMMISSIONER OF INTERNAL REVENUE, v. COMMONWEALTH IMPROVEMENT CO.

Supreme Court of United States.

Decided December 12, 1932.

Attorney(s) appearing for the Case

Assistant Attorney General Youngquist, with whom Solicitor General Thacher, and Messrs. Whitney North Seymour, Sewall Key, and John H. McEvers were on the brief, for petitioner.

Mr. Schofield Andrews, with whom Mr. Ellis Ames Ballard was on the brief, for respondent.

MR. JUSTICE McREYNOLDS delivered the opinion of the Court.

Respondent — Commonwealth Improvement Company — all of whose shares are owned by the Estate of P.A.B. Widener (he died in 1915), made return concerning income and excess profits taxes for 1920 wherein it claimed deduction for loss occasioned by transfer of British-American Tobacco Company stock to the Estate. The Commissioner refused to allow the deduction and found that rightly regarded the...

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