S. Silberman & Sons v. Commissioner

FITZHENRY, Circuit Judge.

This is an appeal from a judgment of the United States Board of Tax Appeals sustaining the determination of respondent that an asserted deficiency deducted by petitioner on its return for the year 1925 did not constitute an allowable deduction for income tax purposes. The loss which petitioner claims to have sustained arose out of a sale of its subsidiary’s capital stock.

The facts are stated in the opinion of the Board:

“S. Silberman & Sons is an Illinois corporation, with its principal office at Chicago. Wm. E. Voelkel & Son Co., Inc., is a Louisiana corporation, with…