United States Board of Tax Appeals September 8, 1925, Docket No. 1954 (Appeal of Lutz)

*485OPINION.

Marquette:

The taxpayer contends that the $23,000 paid as an assessment on his stock during 1922 is a deductible loss in that year.

The question presented is whether or not the sum paid as an assessment was a loss or an additional investment of capital. On the facts before us we are clearly of opinion that the assessment was an additional investment of capital.