Royal Little v. Commissioner of Internal Revenue

HARTIGAN, Circuit Judge.

This is a petition for review of a decision of the Tax Court of the United States, 31 T.C. 607, which determined a deficiency in income tax against the petitioners.

Petitioners Royal Little and Augusta W. E. Little are husband and wife who filed a joint return for the calendar year 1950. The sole concern on review is the Tax Court’s determination in respect to a deduction claimed by petitioners for a loss sustained in 1950. The transaction which led to this claim of deduction was shown in the record as follows. On February 15, 1949 petitioner Augusta W. E. Little…