Cavedon v. Commissioner

*367OPINION.

McMahon :

The question here presented is whether the petitioner sustained net losses during the years 1927 and 1928, within the mean*368ing of section 117 of the Revenue Act of 1928, which may be applied as deductions against the petitioner’s income for the year 1929. Portions of section 117 of the Revenue Act of 1928 are set forth in the margin.1 See art. 651, Reg. 71, as amended by T.D. 4849. The definition of “ net loss ” is substantially the same in the Revenue Act of 1926 as it is in the Revenue Act of 1928.

The net loss of $8,662.75 shown by petitioner’s return for the year 1927 was…