HELVERING v. WILMINGTON TRUST CO.

No. 7662.

124 F.2d 156 (1941)

HELVERING, Com'r of Internal Revenue, v. WILMINGTON TRUST CO. et al.

Circuit Court of Appeals, Third Circuit.

September 3, 1941.


Attorney(s) appearing for the Case

Morton K. Rothschild, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, Sp. Asst. to Atty. Gen., on the brief), for petitioner.

Wm. S. Potter and William L. Hennessy, both of Wilmington, Del. (Simon F. Mcland, Berl, Potter & Leahy, of Wilmington, Del., on the brief), for respondent.

Before CLARK, JONES, and GOODRICH, Circuit Judges.


CLARK, Circuit Judge.

Taxpayer maintained several security accounts with her brokers. In computing her income tax for 1934 and 1935 taxpayer deducted the sums charged as dividends to her short account from the dividend credits on her long accounts. The Commissioner of Internal Revenue assessed a deficiency for the amount of the deduction on the theory that the accounts were separate. The Board of Tax Appeals refused to uphold the deficiency because it viewed the separation...

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