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LITTLE v. HELVERING

No. 10038.

75 F.2d 436 (1935)

LITTLE v. HELVERING, Commissioner of Internal Revenue.

Circuit Court of Appeals, Eighth Circuit.

February 11, 1935.

Attorney(s) appearing for the Case

Benjamin H. Saunders, of Washington, D. C. (Charles D. Hamel and Lloyd Anderson, both of Washington, D. C., on the brief), for petitioner.

L. W. Post, Sp. Asst. to Atty. Gen. (Frank J. Wideman, Asst. Atty. Gen., and Sewall Key, Sp. Asst. to Atty. Gen., on the brief), for respondent.

Before SANBORN, WOODROUGH, and BOOTH, Circuit Judges.

SANBORN, Circuit Judge.

This is a petition to review an order of the Board of Tax Appeals. 27 B. T. A. 1022.

It is charged (1) that the Board erred in disallowing a deduction of $56,133.28 from the taxpayer's gross income for the year 1924, claimed to be a bad debt ascertained to be worthless and charged off, or a loss sustained; and (2) that the Board erred in sustaining a negligence penalty imposed by the respondent.

The applicable statute is the...

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