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ADDA v. COMMISSIONER

Docket No. 8834.

10 T.C. 273 (1948)

FERNAND C. A. ADDA, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 10, 1948.

Attorney(s) appearing for the Case

Mitchell B. Carroll, Esq., Rollin Browne, Esq., and John J. Smith, Esq., for the petitioner.

William F. Evans, Esq., for the respondent.

The primary issue here is whether petitioner, a nonresident alien, was engaged in trade or business in the United States or had an office or place of business in the United States in 1941. If so, the further issues arise as to whether he may deduct certain losses in computing his 1941 net capital gain. The respondent determined a deficiency of $124,598.54, and by his answer to the second amended petition he claims an additional deficiency...

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