Moore v. Hoey

CONGER, District Judge.

Plaintiff seeks to recover allegedly overpaid income taxes for the year 1933, arising from the failure of the Commissioner of Internal Revenue, to allow as deductions, claimed losses due to worthlessness, in that year, of shares of stock of the Continental Corporation of New York (hereinafter referred to as the Corporation), and Sahoff Building Company, Inc.

A stipulation of facts (Plaintiff’s Exhibit 1), together with certain exhibits, comprises the only evidence before the Court.

Plaintiff filed in proper time his individual income tax return for the year 1933. He paid…