Hancock v. Commissioner of Internal Revenue

SWAN, Circuit Judge.

The deficiency in the taxpayer’s income tax results from the disallowance of two deductions, one claimed as a loss sustained on corporate stock which became worthless in 1933, the other claimed as a bad debt that was charged off on the taxpayer’s books in that year. The question presented is wliether there is substantial evidence to support the Board’s finding that neither stock nor debt became worthless during the taxable year. No testimony was introduced except that of the taxpayer and the facts are not in dispute.

Prior to the year 1933 the taxpayer had purchased 67…