Tsivoglou v. United States

MORRIS, District Judge.

TMs is a petition for the recovery- of taxes amounting to $44,042.75, claimed to have been illegally collected from the petitioner with respect to his income for the year 1919. In the District Court judgment went against the petitioner. The only question is whether upon the facts the petitioner was entitled under the Revenue Act of 1918 (40 Stat. 1057) to deduct from his income for the year 1919 the sum of $149,700 as a loss which would have resulted in no taxable income for that year.

The petitioner had been engaged in the confectioners supply business in Boston since…