Gamm v. Commissioner

FOSTER, Circuit Judge.

The petitioner returned net losses on a general merchandising business conducted at Belcher, La., of $4,341.21 and $4,077.20 for the years 1920 and 1921 respectively. The Commissioner of Internal Revenue rejected the returns, and, using the percentage basis, found the petitioner had realized income from his business of $3,372.68 and $2,796.42 for the respective years.

In 1919, petitioner and two others acquired an undivided one-fourth interest in two oil leases on land in Claiborne Parish, La., for $2,472 cash, of which petitioner paid $824, or one-third. In 1920, the…