Hammitt v. Commissioner of Internal Revenue

THOMPSON, Circuit Judge.

This is a petition for review of a decision of the Board of Tax Appeals. The main facts were stipulated and are substantially as follows: During and prior to the year 1929, the petitioner was a member of the Philadelphia Stock Exchange and conducted his business under the firm, name of Hammitt & Co. He engaged in three classes of.stock transactions: First,, the purchase of securities for resale to customers, in which he made a profit or loss,, as the case might be. In this, he acted as-a dealer in securities. Second, the purchase of securities on behalf of his…