United States Board of Tax Appeals October 30, 1940, Docket Nos. 99300, 99301 (Lawson v. Commissioner)

*1107OPINION.

Hitn:

The issue submitted for decision is whether or not petitioners are entitled to deduct from gross income for the taxable year 1936 the stipulated basis of the shares of preferred stock of the Southwest Utility Dairy Products Co. owned by them, respectively. Eespondent disallowed the deductions claimed by petitioners on the ground that the losses were sustained in a prior year.