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THAL v. COMMISSIONER

Docket No. 109994.

2 T.C.M. 123 (1943)

Joseph Thal v. Commissioner.

United States Tax Court.

Entered May 24, 1943.

Attorney(s) appearing for the Case

Murray Smith, Esq., for the petitioner. J. O. Durkan, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The respondent determined a deficiency of $8,150.18 in the petitioner's income tax for the year 1939.

The issues are:

(1) The deductibility of a capital loss alleged to have been sustained on the sale of 70 shares of American General Corporation stock (exchanged for 700 shares of United Founders Corporation stock formerly owned by the petitioner).

(2) The deductibility of a loss on account of the worthlessness...

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