Winmill v. Commissioner of Internal Revenue

MANTON, Circuit Judge.

Petitioner seeks a review of an income tax deficiency, charged against' him for 1932. For several years prior to and during 1932, he was a member of a partnership engaged in the stock brokerage business. During 1932 petitioner ran three separate securities trading accounts which were his own. These operations involved 419 separate sales of 61,992 shares which had been acquired in 353 separate purchases. The cost of-these shares was $2,884,-531.14, exclusive of purchase commissions amounting to $8,911. Of this $8,911, $7,-493.50 was paid in 1932 and $1,417.50 in 1931. On…