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NUTTER v. COMMISSIONER

Docket No. 6608.

5 T.C.M. 4 (1946)

Charles L. Nutter and Helen D. Nutter v. Commissioner.

United States Tax Court.

Entered January 7, 1946.

Attorney(s) appearing for the Case

W. A. Seifert, Esq., 747 Union Trust Bldg., Pittsburgh, Pa., and Sidney B. Gambill, Esq., for the petitioners. Karl W. Windhorst, Esq., for the respondent.

Memorandum Opinion

SMITH, Judge:

This proceeding involves a deficiency of $1,707.91 in petitioners' income tax for 1941. Petitioners allege that respondent erred in determining that they realized a capital gain from a transaction in which petitioner Charles L. Nutter assigned to a bank securities which the bank held as collateral on his loan in settlement of his obligations to the bank. Petitioners contend that the transaction resulted in a capital loss...

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