Huey v. Commissioner

*371OPINION.

Smith:

The Kevenue Act of 1918 permits a taxpayer to deduct from gross income in an individual tax return “losses sustained during the taxable year and not compensated for by insurance or otherwise, if incurred in trade or business.” Section 214(a)(4). The taxpayer claims the right to deduct from gross income certain investments in oil leases in wildcat territory, upon the ground that the leases became worthless during the year 1920, such worthlessness being proven by the fact of wells being drilled during the year coming in “ dry.”

The Commissioner has disallowed the deduction upon the…