Harris v. Commissioner

HUXMAN, Circuit Judge.

Petitioner has appealed from a ruling of the Board of Tax Appeals denying him the right to deduct from his 1935 income tax, as an ordinary business loss incurred during the taxable year of 1935, the sum of $30,234.06, the difference between the cost of stock which he owned and the liquidating dividend received by him during that year.

On January 31, 1924, petitioner purchased 409 shares of the capital stock of the Main Street Arcade Company, a corporation, for a consideration of $22,620. On September 20, 1926, he purchased 240 additional shares at a cost of $9,600. The…