Pioneer Cooperage Co. v. Commissioner of Int. Rev.

MARTINEAU, District Judge.

This is a petition to review an order of the Board of Tax Appeals and involves a construction of section 234 (a) (4) of the Revenue Act of 1918 (40 Stat. 1077), allowing to. a corporation deductions for “losses sustained during the taxable year and not compensated for by insurance or otherwise.”

The facts are not in dispute. Several years prior to 1913, petitioner, a corporation engaged in the timber business, acquired by purchase certain timber lands in Louisiana, which it owned March 1, 1913. In June, 1916, 2,780 acres of petitioner’s timber was damaged by a…