SONNABEND v. C. I. R.

No. 6841.

377 F.2d 42 (1967)

Roger P. SONNABEND et al., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals First Circuit.

Decided May 16, 1967.


Attorney(s) appearing for the Case

David Burstein, Boston, Mass., with whom Hale & Dorr, Boston, Mass., was on brief, for petitioners.

Stephen H. Paley, Atty., Dept. of Justice, with whom Mitchell Rogovin, Asst. Atty. Gen., and Lee A. Jackson and Grant W. Wiprud, Attys., Dept. of Justice, were on brief, for respondent.

Before ALDRICH, Chief Judge, WOODBURY and COFFIN, Circuit Judges.


ALDRICH, Chief Judge.

The sole question in this petition to review a decision of the Tax Court is whether taxpayer was properly limited by section 270 of the Internal Revenue Code of 1954 in respect to deductions allowable to his cattle farm business in 19581 to $50,000. But for this statute, he was admittedly entitled to a loss deduction of $82,363.

Section 270(a) provides, "If the deductions allowed by this chapter * * (other...

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