Jenkins v. Bitgood

SWAN, Circuit Judge.

This is an appeal from a judgment for the defendant in an action brought by the executors of Leonard A. Jenkins, deceased, to recover money alleged to have been wrongfully exacted by the defendant collector of internal revenue as income taxes for the year 1932. It presents the question whether the taxpayer, now deceased, was entitled to a deduction of $19,450 from his 1932 gross income as a loss sustained on an investment in hank stock which became worthless during that year. The case was tried to the court without a jury. Upon special findings of fact the trial judge…