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HELLMAN v. HELVERING

No. 5869.

68 F.2d 763 (1934)

HELLMAN v. HELVERING.

Court of Appeals of the District of Columbia.

Decided January 2, 1934.

Attorney(s) appearing for the Case

Wilton H. Wallace, of Washington, D. C., for petitioner.

G. A. Youngquist, Sewall Key, F. Edward Mitchell, C. M. Charest, W. R. Lansford, Shelby S. Faulkner, and F. W. Dewart, all of Washington, D. C., for respondent.

Before MARTIN, Chief Justice, and ROBB, HITZ, and GRONER, Associate Justices.

GRONER, Associate Justice.

In 1922 petitioner invested $150,000 in the shares of the capital stock of a New York corporation. The 1,500 shares of the par value of $100 each then issued to him were all of the issued stock of the corporation, and he continued to be the sole stockholder from the organization of the company to the event out of which this controversy grows. In the years 1922 to 1926, both inclusive, the corporation sustained operating losses,

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