COMMISSIONER OF INTERNAL REVENUE v. HALES

No. 5187.

76 F.2d 916 (1935)

COMMISSIONER OF INTERNAL REVENUE v. HALES.

Circuit Court of Appeals, Seventh Circuit.

May 6, 1935.


Attorney(s) appearing for the Case

Frank J. Wideman, Asst. Atty. Gen., Sewall Key and Warren F. Wattles, Sp. Assts. to Atty. Gen., and John MacC. Hudson, of Washington, D. C., for petitioner.

Edward Sonnenschein, Herbert M. Lautmann, I. E. Ferguson, and Leonard M. Rieser, all of Chicago, Ill., for respondent.

Before EVANS, SPARKS, and ALSCHULER, Circuit Judges.


EVANS, Circuit Judge.

Petitioner denies, and respondent affirms, the existence of sufficient evidence to sustain the finding of the Board of Tax Appeals to the effect that a sale by him of notes on December 24, 1926, at a loss of $42,200 was bona fide. This appeal reviews the determination of this single issue.

The evidence may be described as conflicting. Perhaps it would be more accurate to say that the assertions of honest intention and good faith were...

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