Ernest W. Brown, Inc. v. Commissioner of Internal Revenue

The question raised by the petition for review is whether the taxpayer incurred a deductible loss in 1952, under Section 23(f) of the Internal Revenue Code of 1939, 26 U.S.C. § 23(f), when two contracts under which taxpayer was acting as attorney-in-fact .for certain insurance underwriters of reciprocal insurance were terminated by the underwriters. This, in turn, depends upon whether the contracts had any basis in the hands of the taxpayer. A complete statement of facts is contained in the opinion of the Tax Court, 28 T.C. 682, sustaining the Commissioner's disallowance of the loss claimed…