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WILLCUTS v. BUNN

No. 22.

282 U.S. 216 (1931)

51 S.Ct. 125

75 L.Ed. 304

WILLCUTS, COLLECTOR OF INTERNAL REVENUE, v. BUNN.

Supreme Court of United States.

Decided January 5, 1931.

Attorney(s) appearing for the Case

Assistant Attorney General Youngquist, with whom Attorney General Mitchell, and Messrs. J. Louis Monarch and Morton Poe Fisher, Special Assistants to the Attorney General, Clarence M. Charest, General Counsel, and T.H. Lewis, Jr., Special Attorney, Bureau of Internal Revenue, were on the brief, for petitioner.

Mr. Charles Bunn for respondent.

Messrs. Joseph E. Warner, Attorney General of Massachusetts, R. Ammi Cutter, Assistant Attorney General, and Henry F. Long, Commissioner of Corporations and Taxation, by special leave of Court, filed a brief on behalf of the Commonwealth of Massachusetts as amicus curiae.

Messrs. Hamilton Ward, Attorney General of New York, and Henry S. Manley, Assistant Attorney General, by special leave of Court, filed a brief on behalf of the State of New York as amicus curiae.

MR. CHIEF JUSTICE HUGHES delivered the opinion of the Court.

The respondent, Charles W. Bunn, in the years 1919 and 1920, purchased for cash, as investments, bonds issued by various counties and cities in the State of Minnesota. In January, 1924, he sold these bonds, realizing a net profit of $736.26. Upon this net profit, less a net loss of $41.20 suffered by him on similar bonds held less than two years, the Commissioner of Internal Revenue determined an additional...

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