Hord v. Commissioner of Internal Revenue

MARTIN, Circuit Judge.

The tax court upheld determination by the Commissioner of Internal Revenue of a deficiency in the petitioning taxpayer’s income tax for 1938. Two questions are presented on this review: (1) whether the petitioner sustained the burden of proving that the Commissioner erred in determining that $19,503 was the gain realized by the taxpayer from the redemption on September 15, 1938, of 297 shares of preferred stock of the Ohio Oil Company at $110 per share; and (2) whether the petitioner sustained the burden of proving that the Commissioner erred in disallowing deductions…