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HELVERING v. MORGAN'S, INC.

No. 12.

293 U.S. 121 (1934)

HELVERING, COMMISSIONER OF INTERNAL REVENUE, v. MORGAN'S, INC. ET AL.

Supreme Court of United States.

Decided November 5, 1934.

Attorney(s) appearing for the Case

Mr. H. Brian Holland, with whom Solicitor General Biggs, Assistant Attorney General Wideman, and Messrs. James W. Morris and John H. McEvers were on the brief, for petitioner.

Mr. Lawrence E. Green, with whom Mr. Haskell Cohn was on the brief, for respondents.

MR. JUSTICE STONE delivered the opinion of the Court.

This petition for certiorari, 292 U.S. 618, presents for determination the single question, whether the two separate periods in 1925, for which the taxpayer made separate income tax returns, constitute two "taxable years" within the meaning of § 206 of the Revenue Act of 1926, c. 27, 44 Stat. 9, 17, which permits the taxpayer suffering a net loss in any taxable year to deduct it from taxable gains in the two...

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