ADLER v. COMMISSIONER

Docket No. 6406.

8 T.C. 726 (1947)

ERNEST ADLER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 31, 1947.


Attorney(s) appearing for the Case

Benjamin Mahler, Esq., for the petitioner.

Fred R. Tansill, Esq., for the respondent.


Respondent determined a deficiency in petitioner's income tax liability for the year 1941 in the amount of $3,595.57. The deficiency results in part from the disallowance of a loss claimed as arising from stock in a French company. The question is whether petitioner is entitled to a loss deduction in 1941 on account of his stock interest in the French company under section 23 (e) or section 127 of the Internal Revenue Code. Petitioner filed a return for 1941 with the collector...

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