Davidson v. Commissioner of Internal Revenue

VAN VALKENBURGH, Circuit Judge.

This case was heard before the Board of Tax Appeals, and now by this court on petition for review, in connection with a companion case, 94 F.2d 300, in which the taxpayer’s husband, James E. Davidson, was petitioner. The facts, in so far as they concern the question here presented, are that Mrs. Davidson was the owner of 400 shares of stock of the American Gas & Electric Company. They were deposited with the First National Bank of Omaha as security for a loan. These shares formed part of a holding of 1,100 shares of the same stock, upon which had been declared a…