Claude P. Brown and Grace W. Brown v. United States
Court of Appeals for the Seventh Circuit
1Opinion of the Court
CUDAHY, Circuit Judge.
The district court granted summary judgment in favor of the government on Claude P. Brown’s tax refund claim, concluding that Brown had failed to adduce sufficient evidence of bona fide losses during the year in question, 1984. We reverse and remand.
I
In October 1981 Claude P. Brown 1 opened a trading account with the Houston, Texas office of ContiCommodity Services, Inc. (Conti). In 1982 Brown opened other accounts that were owned jointly by Brown and his business associate, Isaac C. Hem-mings. David Ragan, who managed Con-ti’s Houston office, performed the trading of…
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