Stephenson v. Commissioner of Internal Revenue

DAVIS, District Judge.

This is a petition to review a decision of the United States Board of Tax Appeals affirming the action of the Commissioner of Internal Revenue in asserting a deficiency of income tax for the year 1921 in the sum of $975.71, and for the year 1922, in the sum of $1,701.84 against appellant.

The appellant claims that he was entitled to certain deductions from income under see tion 214(a) of the Revenue Act of 1921 (42 Stat. 239, 240), providing that in computing income there shall be allowed as deductions:

“(4) Losses sustained during the taxable year and not compensated for…