Snyder v. Commissioner of Internal Revenue

WOOLLEY, Circuit Judge.

The petitioner had been dealing in the stock of the United Gas Improvement Company. Operating through two brokerage houses he acquired during the year 1924 thirty-four hundred shares through thirty-four transactions of purchase.and sold none. During the year 1925 he acquired fourteen hundred shares through sixteen transactions of purchase and sold twenty-one hundred shares through eleven transactions of sale. Thus the purchases were, approximately, in one hundred share lots and the sales in two hundred share lots.

He was dealing on margin and pyramiding his purchases…