Hellman v. Helvering

GRONER, Associate Justice.

In 3922 petitioner invested $150,000 in the shares of the capital stock of a New York corporation. The 3,500 shares of the par value of $100 each then issued to him were all of the issued stock of the corporation, and-he continued to be the sole stockholder from the organization of the company to the event out of which this controversy grows. In the years 1922 to 3.926, both inclusive,' the corporation sustained operating losses, *764the total of which, as of December 1, 1926, was $26,271.58. On January 19, 1927, petitioner caused a resolution to be adopted at a…