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CONNELLY v. COMMISSIONER OF INTERNAL REVENUE

No. 7603.

121 F.2d 686 (1941)

CONNELLY v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

June 23, 1941.

Attorney(s) appearing for the Case

J. S. Seidman, of New York City, for petitioner.

Hubert L. Will, of Washington, D. C. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and Michael H. Cardozo, IV, Sp. Assts. to the Atty. Gen., on the brief), for respondent.

Before MARIS, CLARK, and JONES, Circuit Judges.

JONES, Circuit Judge.

The petitioner deducted in his income tax return for 1934 a loss on account of certain bank stock which he alleges became worthless during the taxable year. The Commissioner disallowed the deduction1 and assessed a deficiency tax accordingly. The Commissioner's notice of the assessment assigned, as the basis for his action, that the bank stock could not "be considered worthless...

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