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STEPHENSON v. COMMISSIONER OF INTERNAL REVENUE

No. 7580.

101 F.2d 33 (1939)

STEPHENSON v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Sixth Circuit.

January 11, 1939.

Attorney(s) appearing for the Case

Wm. J. Murray, of Detroit, Mich. (Wm. J. Murray, of Detroit, Mich., on the brief), for petitioner.

W. F. Wattles, of Washington, D. C. (James W. Morris, J. Louis Monarch, and S. Dee Hanson, all of Washington, D. C., on the brief), for respondent.

Before HICKS, SIMONS, and ALLEN, Circuit Judges.

SIMONS, Circuit Judge.

The petitioner challenged before the Board of Tax Appeals a deficiency determined by the Commissioner in his income tax return for 1929. The deficiency resulted from the disallowance by the respondent of a deduction for losses sustained in 1928 on stock of real estate corporations which had become worthless. While conceding that the losses had been sustained, the respondent determined that they were not attributable to the operation of a trade...

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