deCoppet v. Commissioner

*1392OPINION.

SteRnhagan :

The petitioners demand a deduction in 1933 for loss because of the worthlessness of the shares of the Continental Corporation of New York, the “investment corporation.” The Commissioner disallowed the deduction for the reason that “* * * no part of the cost of the [bank] stock can be allocated to the [investment corporation] stock.”

The shares of the investment corporation were owned by the trustees, and the petitioners’ interest in them was that of beneficiaries of the trust, a position which was always incidental to their ownership of shares in the bank. Notwithstanding…