ANDERSON v. WILSON

No. 460.

289 U.S. 20 (1933)

ANDERSON, COLLECTOR OF INTERNAL REVENUE, v. WILSON ET AL., EXECUTORS.

Supreme Court of United States.

Decided March 13, 1933.


Attorney(s) appearing for the Case

Assistant Attorney General Rugg, with whom Solicitor General Thacher, Assistant Attorney General Youngquist, Miss Helen R. Carloss, and Messrs. Sewall Key and Erwin N. Griswold were on the brief, for Anderson, Collector.

Mr. George E. Cleary, with whom Mr. Clark T. Brown was on the brief, for Wilson et al., Executors.


MR. JUSTICE CARDOZO delivered the opinion of the Court.

The question to be decided is whether the difference between the value of real estate at the death of a testator and the proceeds realized thereafter upon a sale by the trustees may be deducted as a loss by the taxpayer, the beneficial owner of the proceeds, upon his return to the collector for the income of the year.

Richard T. Wilson, Sr., a resident of New York, died in November, 1910, the owner of...

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