SYER v. UNITED STATES

No. 9850.

380 F.2d 1009 (1967)

Chas. SYER, Jr., and Virginia B. Syer, Appellees, v. UNITED STATES of America, Appellant.

United States Court of Appeals Fourth Circuit.

July 5, 1967.


Attorney(s) appearing for the Case

Solomon L. Warhaftig, Attorney, Department of Justice (Louis F. Oberdorfer, Asst. Atty. Gen., and Lee A. Jackson and David O. Walter, Attorneys, Department of Justice, and Claude V. Spratley, Jr., U. S. Atty., and William T. Mason, Jr., Asst. U.S. Atty., on brief), for appellant.

T. L. Sawyer (John M. Hollis and Willcox, Cooke, Savage & Lawrence, Norfolk, Va., on brief), for appellees.

Before HAYNSWORTH, Chief Judge, SOBELOFF, Circuit Judge, and STERLING HUTCHESON, District Judge.


HAYNSWORTH, Chief Judge.

The Commissioner of Internal Revenue challenges the sufficiency of the evidence to support jury findings that a taxpayer was engaged in the business of dealing in corporations and that certain losses, deducted by the taxpayer as business bad debts, were incurred in connection with that business. We are of the opinion that the record does not contain sufficient evidence to support the second finding...

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