MILLER v. COMMISSIONER OF INTERNAL REVENUE

No. 9463.

115 F.2d 479 (1940)

MILLER v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

November 13, 1940.


Attorney(s) appearing for the Case

F. David Mannoccir, II, of San Francisco, Cal., for petitioner.

Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, Maurice J. Mahoney, and Michael H. Cardoza, IV, Sp. Assts. to Atty. Gen., for respondent.

Before WILBUR, GARRECHT, and HEALY, Circuit Judges.


HEALY, Circuit Judge.

The case is here on petition to review a decision of the Board of Tax Appeals upholding the determination of a deficiency in petitioner's income tax for 1933.

During the calendar years 1932 and 1933 petitioner was engaged in business as a trader in securities. In 1932 he sustained a net loss in his business operations. He carried the loss forward and claimed it as a deduction from gross income in his return for the calendar year 1933...

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