Shiman v. Commissioner of Internal Revenue

L. HAND, Circuit Judge.

In July, 1920, Shiman, the taxpayer, guaranteed four brokers’ accounts for his brother-in-law, Oppenheim, who was speculating in stocks. One of these was Oppenheim’s own,, one was Shiman’s, one belonged to Oppen-heim’s wife, in the fourth Shiman and others were interested. At the time of the guaranty Shiman thought Oppenheim solvent, as he was, and the transaction was of the ordinary kind, though influenced no doubt by the relationship of the two. Thereafter, Oppen-heim fell into financial straits and became insolvent, though he still retained a small salary susceptible…