Commissioner of Internal Revenue v. Charavay

BUFFINGTON, Circuit Judge.

The question involved in this case is whether there was substantial evidence to support the Board's finding that the partnership of Stevens and Legg, of which the respondent was a member, was a dealer in securities during the years 1929 and 1930, and therefore entitled to the use of inventories in computing its income for those years. The Commissioner held against the taxpayer; the Tax Board in his favor. In so doing the Tax Board discussed in detail the situation in its reversing opinion, and reference thereto saves needless repetition. It grasped and decided the…