Holmes v. Commissioner of Internal Revenue

MANTON, Circuit Judge.

Petitioner entered in the business of buying and selling securities in 1925 and until the year 1930 bought and sold a considerable volume. Some of these were listed on the exchange and many were unlisted securities. The Board found he was a dealer in securities.

On January 3, 1927, he purchased 33,-834 shares of stock of the Domestic Electric Refrigerator Corp., a company which had been formed to take over some patents. Petitioner understood at the time of the purchase that a public offering of the stock would be made. Dissatisfied with the progress and operation of the…