Klingenstein v. United States

LITTLETON, Judge.

The question presented is whether plaintiff was entitled to offset his individual losses amounting to $32,144.95, which arose from the sale of securities held by him for less than two years, against his share of the net income of the partnership), of Wertheim & Co., of which he was a. member, when the net profits of the partnership resulted from the sale of securities which the partnership had held for less than two years. We are of opinion, that the plaintiff was not entitled to the deductions claimed.

In Archbald v. Commissioner, 27 B.T.A. 837, the government advanced the…