Commissioner v. Ehrhart

WALKER, Circuit Judge.

In his income tax return for the year 1930, the respondent claimed as a deductible loss the sum of $9,999, being the difference between the price, $10,000, paid by respondent in 1915 for 100 shares of the stock of the Consolidated Company, an Illinois corporation (which stock was surrendered to that corporation for 60 shares of its stock, that exchange resulting in neither gain nor loss), and the amount $1, for which respondent transferred that stock to his son in December, 1930. The Commissioner disallowed that deduction. On a petition for a redetermination of the…