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ROOT v. COMMISSIONER OF INTERNAL REVENUE

No. 14151.

220 F.2d 240 (1955)

Louise F. ROOT, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Ninth Circuit.

March 7, 1955.

Attorney(s) appearing for the Case

Henry W. Howard, San Francisco, Cal., for appellant.

H. Brian Holland, Asst. Atty. Gen., Karl Schmeidler, Atty., Dept. of Justice, Washington, D. C., Joseph F. Goetten, Ellis N. Slack, Lee A. Jackson, Special Assts. to Atty. Gen., Daniel A. Taylor, chief counsel, Internal Revenue Service, Washington, D. C., for appellee.

Before HEALY and CHAMBERS, Circuit Judges, and WIIG, District Judge.

HEALY, Circuit Judge.

This case is here on petition to review a decision of the Tax Court upholding a deficiency assessment in respect of petitioner's income tax for the year 1945. In her return for that year petitioner claimed a deduction of $12,910.20 assertedly representing unrecoverable loans to the Washington Hills Quicksilver Corporation. The Commissioner disallowed the deduction on the ground that the amount claimed was not a bad debt but a capital investment...

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