Du Pont v. Commissioner

BIGGS, Circuit Judge.

The petitioner was indebted to Bankers Trust Company of New York which called upon him either to deposit additional collateral or reduce the amount of his loan. The petitioner had 90,000 shares of duPont Company stock with Bankers Trust Company as security for this loan. He thereupon made an agreement with Christiana Securities Company to sell to it, and Christiana agreed to buy from the petitioner 62,500 shares of duPont Company stock for $2,000,-000. This agreement was made on April 20, 1932. The petitioner thereupon employed Raymond Ellis to carry out the transaction.…