Louis N. POKRESS and Estate of Lucille A. Pokress, Deceased, Louis N. Pokress, Executor, Petitioners,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent.
United States Court of Appeals Fifth Circuit.https://leagle.com/images/logo.png
May 25, 1956.
Rehearing Denied August 28, 1956.
Attorney(s) appearing for the Case
Wm. G. Ward, Miami, Fla., Ward & Ward, Miami, Fla., for appellants.
Grant W. Wiprud, Atty., Dept. of Justice, Tax Div., Washington, D. C., H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Sp. Asst. to Atty. Gen., John Potts Barnes, Chief Counsel, Int. Rev. Service, Washington, D. C., Vernon F. Weekley, Sp. Atty., Robert N. Anderson, A. F. Prescott, Walter Akerman, Jr., Attys., Dept. of Justice, Washington, D. C., for respondent.
Before HUTCHESON, Chief Judge, and RIVES and BROWN, Circuit Judges.
United States Court of Appeals Fifth Circuit.
RIVES, Circuit Judge.
The Tax Court held that the petitioner1 in the taxable year 1946 sustained a non-business bad debt loss in the amount of $16,222.77 deductible under the provisions of Section 23(k) (4) of the 1939 Internal Revenue Code.2 The petitioner insists that the Tax Court erred: (1) in refusing to find from the overall transaction a deductible loss incurred in trade or business or in a transaction...
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