White v. United States

The question decisive of this case is whether, under §§ 23 and 101 of the Revenue Act of 1928, 45 Stat. 791, upon a liquidation of a corporation, stockholders’ losses from their investment in its stock held for more than two years are ordinary losses deductible in full from gross income, or capital losses, 12%% of which is deductible under § 101 from the tax as computed without regard to such losses.

The decedent in each of. these cases made an investment represented by shares of stock in a corporation. Upon complete liquidation of the corporation, more than two years later, the total…