SHIPLEY v. COMMISSIONER

Docket No. 29339.

17 T.C. 740 (1951)

GRANT B. SHIPLEY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 31, 1951.


Attorney(s) appearing for the Case

Sidney B. Gambill, Esq., for the petitioner.

Kalman A. Goldring, Esq., for the respondent.


Petitioner contests respondent's determination of a deficiency of $6,538.33 in income tax for 1945. One adjustment is not contested. The issue is whether petitioner is entitled to a deductible capital loss either by reason of a stock transaction during the taxable year, or, in the alternative, by reason of a capital loss carry-over resulting from the fact of the worthlessness of the stock in question in an earlier year.

FINDINGS OF FACT.

Petitioner, a resident...

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