Wise v. Commissioner

In this case the petitioner seeks to deduct- as an income tax loss in 1933 the cost of his interest in certain shares of stock of the Continental Corporation which was dissolved without assets in that year. The Board of Tax Appeals, considering the cases of this petitioner and a number of other stockholders, decided that the petitioner’s interest in these shares was never an independent investment but at all times merely a part of his investment in the stock of the Continental Bank & Trust Company of New York to which through a trust agreement and certificate endorsement they were indivisably…