Commissioner of Internal Revenue v. Hawkins

Fifth Circuit

Commissioner of Internal Revenue v. Hawkins

91 F.2d 354, 19 A.F.T.R. (P-H) 1116, 1937 U.S. App. LEXIS 4227

Court of Appeals for the Fifth Circuit·Decided July 16, 1937·No. 8397·Published·Cited by 10 cases

Opinion

FOSTER, Circuit Judge.

This case presents merely a question of whether petitioners were entitled to take a deduction on their returns from 1932 for a loss occasioned by the foreclosure of a mortgage and consequent sale of a large tract of land in California in 1931. The facts are not in dispute. The Board in a well-considered opinion, reported in 34 B. T.A. 918, carefully reviewed the law and held that the loss did not occur until the end of the redemption period in 1932.

We concur in the ruling of the Board. The petition is denied and the judgment of the Board is affirmed.

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FOSTER, Circuit Judge.

This case presents merely a question of whether petitioners were entitled to take a deduction on their returns from 1932 for a loss occasioned by the foreclosure of a mortgage and consequent sale of a large tract of land in California in 1931. The facts are not in dispute. The Board in a well-considered opinion, reported in 34 B. T.A. 918, carefully reviewed the law and held that the loss did not occur until the end of the redemption period in 1932.

We concur in the ruling of the Board. The petition is denied and the judgment of the Board is affirmed.

Commissioner of Internal Revenue v. Hawkins, 91 F.2d 354, 19 A.F.T.R. (P-H) 1116, 1937 U.S. App. LEXIS 4227 (5th Cir. 1937).

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Opinion

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