FOSTER, Circuit Judge.
In filing his income tax returns for 1931 petitioner deducted a loss of $62,582.40, occasioned by his stock holdings in Christie and Hobby, Inc., becoming worthless. The Commissioner held that the loss occurred in the taxable year 1930 and not 1931, determined an over assessment of $670.73 for 1930 and a deficiency of $11,010.46 for 1931. The Board of Tax Appeals held that petitioner had failed to overcome the presumption in favor of the correctness...
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