Stiver v. Commissioner of Internal Revenue

SANBORN, Circuit Judge.

This is a petition to review a decision of the Board of Tax Appeals redetermining a deficiency in the income taxes of the petitioner for the year 1930, caused by the dis-allowance of a deduction of $26,904 claimed by the petitioner to represent a loss sustained by him in that year from the sale of his stock in the Somerset Oil Company and from the sale by that company of its entire assets.

There is no substantial controversy as to the controlling facts, which are stated in the opinion of the Board as follows:

“Prior to 1923, petitioner acquired 5,-400 shares of stock in…