J. H. Cooper Enterprises, Inc., and Joseph H. Cooper Estate, Transferee, Austin C. Keough v. Commissioner of Internal Revenue

JOHNSEN, Circuit Judge.

The Tax Court held that J. H. Cooper Enterprises, Inc. was not entitled to a capital-loss deduction, made in its income-tax return for the fiscal year ended June 30, 1948, and that' it was accordingly liable for a tax deficiency. The taxpayer has petitioned for review. 1

The taxpayer had claimed the deduction, on the basis of stock owned by it in J. W. Cooper Corporation, representing an investment of $110,000, having become worthless during the tax year involved, and so being entitled to be charged off in its return for that period. The identifiable event, on which it…