HIRSCH v. C. I. R.

No. 17779.

315 F.2d 731 (1963)

Clement L. HIRSCH, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

March 22, 1963.

Attorney(s) appearing for the Case

Shearer & Fields, Jacob Shearer and Bernard Shearer, Beverly Hills, Cal., for appellant.

Louis F. Oberdorfer, Asst. Atty. Gen., Robert L. Walters, Meyer Rothwacks, Gilbert E. Andrews, and Earl J. Silbert, Attys., Dept. of Justice, Washington, D. C., for appellee.

Before JERTBERG and BROWNING, Circuit Judges, and PENCE, District Judge.

PENCE, District Judge.

This is another tax case involving the question of whether the Tax Court correctly held that the petitioner-appellant (taxpayer) was not entitled to deduct from his federal income taxes certain expenses paid and a worthless debt suffered by him, as not having been incurred in the taxpayer's trade or business.

Such facts as found by the Tax Court which we deem here pertinent may be summarized as follows:

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