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EARLE v. COMMISSIONER

Docket Nos. 18541, 18542.

9 T.C.M. 1181 (1950)

Stewart E. Earle v. Commissioner. G. Harold Earle v. Commissioner.

United States Tax Court.

Entered December 29, 1950.

Attorney(s) appearing for the Case

G. E. H. Goodner, Esq., Munsey Bldg., Washington, D. C., for the petitioners. G. T. Donoghue, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

These proceedings were consolidated for hearing. In Docket No. 18541 the respondent determined a deficiency, in income tax for 1944, of $19,080.84 for Stewart E. Earle. In Docket No. 18542 the respondent determined a deficiency, in income for 1944, of $16,177.22 for G. Harold Earle.

The principal issue is whether each petitioner sustained an ordinary loss in 1944 in a transaction entered into for profit. The respondent...

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