Honomu Sugar Co. v. Commissioner

*347 Before JAMES, LITTLETON, SMITH, and TRUSSELL.

This is an appeal from the determination of a deficiency in income and profits tax for the year 1920 in the amount of $73,628.60. He issue is the method of measuring the loss on the sale of securities.

FINDINGS OF FACT.

The taxpayer is a corporation organized under the laws of the Territory of Hawaii, with its principal office at Honolulu.

*348 Prior to March 1, 1913, the taxpayer purchased 790 shares of stock of Sugar Factories Co., Ltd., at a cost of $79,000. In 1920, the taxpayer sold the stock for $31,584.20. In its income-tax return for 1920, the taxpayer claimed that the stock had a fair market value on March 1, 1913, of $240,428.60, and deducted in its return as its alleged loss the amount of $208,844.40. The Commissioner in the audit of the taxpayer's return limited the loss to $47,415.80, the difference between the cost of the stock and the selling price thereof, and determined the deficiency here in issue.

DECISION.

The determination of the Commissioner is approved.

OPINION.

*2439 JAMES: The decision in this appeal is governed by the decisions of the Supreme Court in , and , decided April 13, 1925.