U.S. Court of Appeals for the D.C. Circuit, 1948

Garrison v. Commissioner

U.S. Court of Appeals for the D.C. Circuit · Decided April 23, 1948

167 F.2d 757; 83 U.S. App. D.C. 396; 36 A.F.T.R. (P-H) 984; 1948 U.S. App. LEXIS 3899 (Federal Reporter, Second Series)

Counsel

Mr. Wilbert Garrison, pro se, submitted on his brief., Mr. Harry Baum, Special Assistant to the Attorney General, of the Bar of the State of New York, pro hac vice, by special leave of Court, with whom Miss Helen R. Car-loss, Special Assistant to the Attorney General, was on the brief, for respondent. Messrs. J. P. Wenchel, Chief Counsel, Bureau of Internal Revenue, and Rollin H. Transue, Special Attorney, Bureau of Internal Revenue, both of Washington, D. C., Sewall Key, Acting Assistant Attorney General, and Newton K. Fox, Attorney, Department of Justice, of Washington, D. C., also entered appearances for respondent.

Opinion of the Court

PER CURIAM.

The Tax Court of the United States found that petitioner’s stock in Independence Indemnity Company, a Pennsylvania corporation dissolved by court decree as insolvent in 1933,, became worthless prior to 1941; with the result that petitioner was not entitled to claim for income tax purposes a loss on a 1941 sale of such stock, for five dollars, which petitioner made at an expense of $52. Petitioner asks us to review this decision and set it aside. We find that the evidence amply supports the decision. In fact we find no evidence that would have supported an opposite decision.

Affirmed.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.