McALLISTER, Circuit Judge.
Petitioners, husband and wife, in their joint income tax return for 1949, claimed a deduction from gross income in the amount of $30,000 on the ground that it was a loss incurred in a transaction entered into for profit and properly allowable to them as a deduction under Section 23(e) (2) of the Internal Revenue Code, 26 U.S.C.A. The Commissioner's denial of the deduction was sustained by the Tax Court.
Petitioner, William B. Cudlip...
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