Ludwig v. Commissioner

SWAN, Circuit Judge.

These appeals present a single question: Whether the taxpayer’s stock in a New Jersey corporation became worthless in the year 1937 so as to entitle him to take the cost thereof as a deductible loss under section 23(e) (2) of the Revenue Act of 1936, 26 U.S.C.A. Int.Rev.Code, § 23(e) (2). The Board sustained the commissioner’s denial of such deduction.

*321There is no dispute as to the evidentiary facts. Prior- to 1937 each of the taxpayers had purchased stock in Bankers Title & Mortgage Guaranty Company. This corporation was organized under the laws of New Jersey and was…