Jesse Johnson and Virginia D. Johnson v. Commissioner of Internal Revenue

PARKER, Chief Judge.

This is a petition to review a decision of the Tax Court of the United States affirming deficiency assessments of income taxes against petitioners, husband and wife, for the years 1947 and 1948, on the ground that certain deductions claimed as losses should hot be allowed. The losses claimed were expenditures made by the husband, whom we shall refer to hereafter as the taxpayer, in constructing a building under contract for Frederick Courts, Inc., a corporation in which he was the sole common stockholder. The question presented by the appeal is whether the Tax Court was…