United States Board of Tax Appeals August 11, 1938, Docket No. 90527. (American Utilization Co. v. Commissioner)

lead-opinion

*326OPINION.

Black::

We shall first take up respondent’s contention that petitioner in 1934 sold to two of its stockholders, Frank and Robert Goldberg, its entire holdings of stock in American Cotton Mills Number Two, and that by reason thereof petitioner did not own any stock in the corporation during the year 1935 and therefore is not entitled to the deduction of any loss by reason