HUMPHREY v. COMMISSIONER OF INTERNAL REVENUE

No. 8318.

91 F.2d 155 (1937)

HUMPHREY v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

June 21, 1937.


Attorney(s) appearing for the Case

Joseph P. Tumulty and Walter E. Barton, both of Washington, D. C., and Adolphus E. Graupner, of San Francisco, Cal. (Robert M. Searls and Willard L. Pope, both of San Francisco, Cal., of counsel), for petitioner.

Robert H. Jackson, Asst. U. S. Atty. Gen., and Sewall Key, Maurice J. Mahoney, and Francis I. Howley, Sp. Assts. to Atty. Gen., for respondent.

Before WILBUR, MATHEWS, and HANEY, Circuit Judges.


WILBUR, Circuit Judge.

The taxpayer in this case claimed a deduction from his gross income by reason of the loss of $126,993.66 during the taxable year ending December 31, 1929. The Commissioner contends, and the Board of Tax Appeals found, that the taxpayer was not entitled to any deduction. The facts were stipulated and are set forth in the findings of the Board of Tax Appeals.

The taxpayer, together with A. J. Crocker Company, the Provident Security Corporation...

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