SHAHMOON v. COMMISSIONER OF INTERNAL REVENUE

No. 15, Docket 21614.

185 F.2d 384 (1950)

SHAHMOON et al. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Second Circuit.

Decided November 29, 1950.


Attorney(s) appearing for the Case

Max Schiller and Jay O. Kramer, New York City, for petitioners.

Theron L. Caudle, Asst. Atty. Gen., Ellis N. Slack and I. Henry Kutz, Sp. Assts. to the Atty. Gen., for Respondents.

Before AUGUSTUS N. HAND, CHASE and CLARK, Circuit Judges.


AUGUSTUS N. HAND, Circuit Judge.

The petitioners are husband and wife residing in New Rochelle, New York. They filed their income tax return for 1944 claiming deduction for depreciation under Section 23(l) of the Internal Revenue Act, 26 U.S.C.A.

The husband had acquired vacant land at Dalny and Ward Roads in Shanghai, China, during the year 1924. About 198 buildings, shops, and houses were erected on the property in 1925. He also acquired land and...

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