The tax-payer’s deduction from its income for the year 1903 of the sum of $150,000 by reason of its estimate of the loss in respect of the Hawaii Mill Company, which it owns, cannot be regarded as a loss “actually sustained during the year.” Sec. 1281, E. L. This estimate of the loss did not become an actual loss by the mere act of writing it off to the account of profit and loss, and it cannot be allowed.

The decision of the tax appeal court is modified accordingly.