Astoria Marine Construction Co. v. Commissioner

OPINION.

Johnson, Judge:

Petitioner settled notes on which it was obligated to Watzek in the amount of $26,000 for a cash payment of $500. They were not purchase money notes, and petitioner bore no relation tothe seller other than that of debtor. Petitioner seeks to characterize the $20,000 loan, which was needed and used in constructing the vessel for the U. S. Coast and Geodetic Survey, as part of a transaction or venture on which it lost money. But such a view was considered and rejected by this Court in petitioner’s prior proceeding, Docket No. 1868, involving tax deficiencies for 1939. We…