Peter Seletos v. Commissioner of Internal Revenue

SANBORN, Circuit Judge.

This Court is asked to review and reverse a decision of the Tax Court of the United States which redetermined a deficiency in the income tax of the petitioner for the year ended December 31, 1952. The Tax Court found as a fact that a loss of $10,013.96 sustained by the petitioner from the sale of a residential property in 1952 was a nondeductible personal loss. The petitioner’s contention was that, under the evidence, the loss was conclusively shown to be a deductible loss under Section 23(e)(2) of the Internal Revenue Code of 1939, 26 U.S.C. (1952 Ed.) Sec. 23(e)(2),…