TRICOU v. HELVERING

No. 7090.

68 F.2d 280 (1933)

TRICOU v. HELVERING, Commissioner of Internal Revenue.

Circuit Court of Appeals, Ninth Circuit.

December 18, 1933.


Attorney(s) appearing for the Case

Joseph D. Brady and George Bouchard, both of Los Angeles, Cal., for petitioner.

Sewall Key and John MacC. Hudson, Sp. Assts. to Atty. Gen. (C. M. Charest, Gen. Counsel, and W. Frank Gibbs, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for respondent.

Before WILBUR, MACK, and GARRECHT, Circuit Judges.


WILBUR, Circuit Judge.

This is an appeal from a decision of the Board of Tax Appeals refusing to allow the petitioner to deduct from her income in 1923 a part of her net loss incurred in 1922, amounting to $236,736.82.

Petitioner sustained a capital loss of $319,387 in 1922 with reference to her interest in Hidalgo Land Securities Syndicate. She claims that as this loss resulted from the operation of a trade or business regularly carried on by her she thereby...

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