The Commissioner determined a deficiency of $3,974.08 in petitioner's income tax for 1932 and a penalty of $993.52 for failure to file a return. Petitioner charges that the Commissioner erred (1) in failing to deduct $24,000 from gross income on account of the alleged worthlessness of petitioner's shares in and loans to a corporation of which he was sole shareholder; (2) by including in taxable income compensation for services rendered as special attorney to the Railroad...
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