Nachod & United States Signal Co. v. Helvering

*166SIMONS, Circuit Judge.

This review involves the petitioner’s income taxes for the calendar years 1923 to 1926, inclusive. The sole issue before the Board was whether or not the respondent erred in disallowing deductions from gross income on account of the exhaustion of value of a group of patents owned by the taxpayer. The determinations of the respondent were approved, and the taxpayer seeks review of the Board’s decision.

We are met at the outset of the case by the respondent’s motion for an affirmance of the decision on the principle of res judicata. The order of redetermination in the…