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BLAIR v. COMMISSIONER OF INTERNAL REVENUE

Nos. 283, 284.

91 F.2d 992 (1937)

BLAIR v. COMMISSIONER OF INTERNAL REVENUE. GLADSTONE CORPORATION v. SAME.

Circuit Court of Appeals, Second Circuit.

July 19, 1937.

Attorney(s) appearing for the Case

Clarence Blair Mitchell, of New York City (Choate, Larocque & Mitchell and H. Henry Ramm, all of New York City, of counsel), for petitioner.

James W. Morris, Asst. Atty. Gen., Sewall Key and Helen R. Carloss, Sp. Assts. to the Atty. Gen., for respondent.

Before MANTON, SWAN, and CHASE, Circuit Judges.

MANTON, Circuit Judge.

Blair's appeal involves a deficiency in income taxes for the year 1929; that of the Gladstone Corporation involves a deficiency in income taxes for the year 1930. These cases were argued together and will be considered in one opinion. The question presented is whether deductible losses were sustained by auction sales in 1929 and 1930 of notes of the International Coal Products Corporation.

Blair and two others were members of the partnership...

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