Reynolds v. Commissioner of Internal Revenue

DOBIE, Circuit Judge.

This case, arising under the federal income tax laws, is before us on the- appeal of R. Foster Reynolds (hereinafter called taxpayer) from a decision of the Tax Court of the United States, holding that the loss incurred by taxpayer from the sale of a piece of jewelry was deductible only to the extent of 50 per cent of the actual loss on the ground that this was a loss resulting from the sale of a capital asset under a transaction entered into for profit. The Tax Court denied the taxpayer’s claim that this loss was fully deductible as a loss incurred from a sale of…