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CANDLER v. COMMISSIONER OF INTERNAL REVENUE

No. 7595.

76 F.2d 548 (1935)

CANDLER v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

April 2, 1935.

Attorney(s) appearing for the Case

Theodore B. Benson, of Washington, D. C., for petitioner.

Frank J. Wideman, Asst. Atty. Gen., Helen R. Carloss, Sewall Key, and Norman D. Keller, Sp. Assts. to Atty. Gen., and Robert H. Jackson, Asst. Gen. Counsel, Bureau of Internal Revenue, and W. F. Gibbs, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before BRYAN, SIBLEY, and WALKER, Circuit Judges.

BRYAN, Circuit Judge.

Petitioner's claim that in computing his income taxes for the year 1924 he was entitled to deduct a loss on bonds of the Couch Cotton Mills, which he held, having been rejected by the Board of Tax Appeals, is brought here for review.

The Board based its decision on section 214 (a) (5), Revenue Act 1924, 26 USCA § 955 (a) (5), which provides for the deduction of losses incurred in transactions entered into for profit. Petitioner contends...

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