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CURTISS v. COMMISSIONER OF INTERNAL REVENUE

No. 6388.

57 F.2d 847 (1932)

CURTISS v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

April 13, 1932.

Attorney(s) appearing for the Case

P. Robert G. Sjostrom, of Miami, Fla., and Wm. S. Hammers, of Washington, D. C., for petitioner.

G. A. Youngquist, Asst. Atty. Gen., John MacC. Hudson and Sewall Key, Sp. Assts. to Atty. Gen., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Eugene Harpole, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before BRYAN, FOSTER, and WALKER, Circuit Judges.

WALKER, Circuit Judge.

Each of the two petitioners sought a redetermination by the Board of Tax Appeals of a deficiency assessed by the respondent, the Commissioner of Internal Revenue, as a result of his disallowance of the amount claimed in an income tax return for the calendar year 1924 as a deduction for an alleged loss resulting from a sale of certificates of beneficial interests of the Curtiss Assets Company, which certificates constituted part of what, in the...

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