Manhattan General Equipment Co. v. Commissioner

AUGUSTUS N. HAND, Circuit Judge.

The first question before us is whether there was any deductible loss in 1925 because of the cancellation of the contract between Artemas Ward and Interborough Rapid Transit on November 1, 1925. This depends on whether the deductions for exhaustion allowed to Artemas Ward between March 1, 1913, and March 13, 1922, when the latter transferred the contract to Artemas Ward, Inc. (N. Y.), in exchange for all the stock of.that corporation, should be added to the deductions for exhaustion allowed to Artemas Ward, Inc. (N. Y.), between, the date of transfer and the…