Herold v. Commissioner of Internal Revenue

BRYAN, Circuit Judge.

This is a petition to review a decision of tbe Board of Tax Appeals which rejected petitioner’s claims that be was entitled, under section 214(a) (10) of tbe Revenue Act of 1921, 42 Stat. 241, to deductions from bis net income during tbe years 1921 and 1922 for depletion of an oil and gas lease based on tbe fair market value thereof at tbe date of discovery of oil, and held him liable for deficiencies assessed by tbe Commissioner of Internal Revenue upon bis net income during those years without making any allowance for such depletion.

Tbe above-cited section of tbe 1921…