Henry Protzmann v. Commissioner of Internal Revenue

HARTIGAN, Circuit Judge.

This is a petition for review of a decision of the Tax Court of the United States, 1959 T. C. Memo. No. 105, which determined a deficiency in income tax against the petitioners.

The petitioners are Henry Protzmann (hereinafter referred to as petitioner) and the estate of Helga K. Protzmann, the deceased wife of Henry Protzmann. Henry and Helga Protzmann filed a joint return for the year 1948. Petitioner claimed a deduction of $38,370.51 as a “loss on brewing venture.” The Commissioner disallowed the deduction, and determined a deficiency of $23,446.26. On petition to…