Liberman's Committee v. Commissioner

SWAN, Circuit Judge.

Tbe deficiencies in question resulted from computation of tbe taxpayer’s net income for the taxable periods in question without allowing any deduction on account of a “net loss” claimed to have been sustained by the taxpayer for the year 1923 under section 204 of tbe Revenue Act of 1921 (42 Stat. 231), and to be deductible under the provisions of section 206 of the Revenue Act of 1924 (43 Stat. 260 [26 USCA § 937 and note]). The Board of Tax Appeals upheld the Commissioner’s determination that no such net loss bad been sustained. Whether this decision was right we need not…