HELVERING v. HAMMEL

No. 49.

311 U.S. 504 (1941)

HELVERING, COMMISSIONER OF INTERNAL REVENUE, v. HAMMEL ET UX.

Supreme Court of United States.

Decided January 6, 1941.


Attorney(s) appearing for the Case

Mr. Norman D. Keller, with whom Solicitor General Biddle, Assistant Attorney General Clark, and Mr. Sewall Key were on the brief, for petitioner.

Mr. John J. Sloan for respondent.


MR. JUSTICE STONE delivered the opinion of the Court.

We are asked to say whether a loss sustained by an individual taxpayer upon the foreclosure sale of his interest in real estate, acquired for profit, is a loss which, under § 23 (e) (2) of the 1934 Revenue Act, 48 Stat. 680, may be deducted in full from gross income for the purpose of arriving at taxable income, or is a capital loss deductible only to the limited...

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