NATIONAL BRONX BANK v. COMMISSIONER OF INT. REV.

No. 97.

147 F.2d 651 (1945)

NATIONAL BRONX BANK OF NEW YORK v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

February 9, 1945.


Attorney(s) appearing for the Case

Meyer D. Siegel and Robert Siegel, both of New York City, for petitioner.

Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, Robert N. Anderson, Irving R. Panzer, and Meyer Rothwacks, Sp. Assts. to the Atty. Gen., for respondent.

Before CHASE, HUTCHESON, and FRANK, Circuit Judges.


HUTCHESON, Circuit Judge.

In the tax years in question, petitioner sold bonds for less than cost and in each year claimed the difference as a deductible loss. The Commissioner disallowed the claim on the ground that the loss had occurred in earlier years and had been then claimed and allowed. This appeal is from a finding and order of the Tax Court sustaining the Commissioner and denying the deductions accordingly. Here petitioner's arguments, presented with a vigor...

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