Sacks v. Commissioner of Internal Revenue

This is a petition to review a decision of the Board of Tax Appeals sustaining the determination of a deficiency against the petitioner in income taxes for the year 1925. The decision of the Board of Tax Appeals is reported in 25 B. T. A. 415.

The questions here presented are: (1) Whether the loss and expense of $44,101.76 sustained and incurred by appellant in connection with his interest in the corporation of Golden & Co. was attributable to the operation of a business regularly carried on by the appellant; (2) whether the said loss and expense of $44,101.76, or any part of it, was sustained…