Rand Co. v. Commissioner

opinion.

Goodeich :

Again we are called upon to determine whether transactions disposing of depreciated securities constituted valid and bona fide sales so that the losses registered may serve to reduce income and thus avoid tax. The primary facts are not in dispute; it is only *468the ultimate finding respecting the character of the transactions which is in controversy. Upon motion, the proceedings were consolidated for hearing.

In December 1929 the Hand Co., a closely held “ family ” corporation, having its principal office in Minneapolis, Minnesota, where it was engaged in buying, selling, and…