Brown v. Commissioner of Internal Revenue

FOSTER, Circuit Judge.

This is a petition to review a decision of the United States Board of Tax Appeals. D. H. Brown, tho taxpayer, an inhabitant of Alabama, residing and doing business in Birmingham, filed his returns of income taxes for tho years 1918,1919, and .1920. Seeking to bring himself within the provisions of: section 214 of the Revenue Act of 1918 (Comp. St. § 6336- Vsg), and similar later statutes, in his returns for 1918 and 1919 he deducted a total of $15,000 as a loss on account of advances made to the Ajax Coal & Mining Company. He owned $9,000 out of a total of $30,000 of the…