Stoddard v. Commissioner of Internal Revenue

FRANK, Circuit* Judge.

1. When these cases were previously here, we remanded to the Tax Court solely for a determination of the value of the new second mortgage bonds at the time of their receipt by taxpayers. Stoddard v. Commissioner, 141 F.2d 76. On the remand, the parties stipulated that the Tax Court should reach its decision on the evidence submitted to it at the first hearing. The Tax Court, acting accordingly, found the bonds worthless in 1936 when received by the taxpayers in exchange for their interests in the old second mortgage note, and, in accordance with our opinion, held the…