Long v. Commissioner of Internal Revenue

STEPHENS, Circuit Judge.

The Commissioner of Internal Revenue disallowed a deduction claimed in petitioner’s income tax return and determined a deficiency in the tax liability of $3,286.17 for the year 1931. She petitioned the Board of Tax Appeals for a redetermination of the deficiency and prayed that, “The Board may find that the taxpayer suffered a deductible loss during the year 1931 in the sum of $112,450.” The Board decided no deduction should be allowed. Petitioner seeks review of this decision.

The undisputed facts are as follows: On January 10, 1929, petitioner and her husband, Marcus…