Rankin v. Commissioner of Internal Revenue

WOOLLEY, Circuit Judge.

The Commissioner of Internal Revenue assessed a deficiency tax against Richard B. Turner for the tax year 1928. Turner petitioned the United States Board of Tax Appeals for a rodetermination of the deficiency. His executor is here on petition to review the order of that tribunal sustaining tho tax.

This case, like that of Snyder v. Commissioner (C. C. A.) 73 F.(2d) 5, arose out of confusion (this time by the Commissioner) in the terms “shares” and “certificates” in transactions of sale of stock on margin as affected by section 113 (a) of the Revenue Act, of 1928 (26 USCA…