Kohn v. Commissioner of Internal Revenue

CLARK, Circuit Judge.

This is a petition for review of a decision of the Tax Court of the United States, 16 T.C. 960, finding a deficiency of $2,336.-76 in the taxpayer’s income tax for 1944. The question turns upon the proper valuation — in computation of a capital loss — of mortgaged property eventually conveyed by the mortgagor to taxpayer as mortgagee. The original loan had been made by taxpayer’s mother in the sum of $12,000 to Beilin Service Corporation and was secured by mortgage on realty of the latter. In 1930, taxpayer acquired the bond and mortgage by gift from his mother. On June…