Helvering v. Price

Respondent in his income tax return for 1932 claimed a deduction for a loss upon a contract of guaranty. The Board of Tax Appeals sustained the Commissioner in refusing to allow the deduction, and the Circuit Court of Appeals reversed. 106 F. 2d 336. Because of an alleged conflict with Eckert v. Burnet, 283 U. S. 140, Jenkins v. Bitgood, C. C. A. 2d, 101 F. 2d 17, and Ferris v. Commissioner, C. C. A. 2d, 102 F. 2d 985, we granted certiorari, 308 U. S. 548.

The facts as found may be thiis summarized: In 1929 the Atlantic Bank and Trust. Company of Greensboro, North Carolina, was merged with the…