Helvering v. Owens et al.
United States Supreme Court
305 U.S. 468, 59 S. Ct. 260, 83 L. Ed. 292 (1939)
Facts
In 1913 Donald H. Owens (plaintiff) bought a car for $1,825. In 1934 Owens wrecked the car. Before the accident, the car was worth an estimated $225. After the accident, the car was worth $190. On his 1934 income-tax return, Owens claimed a loss deduction of $1,635, the total loss of value of the car from its initial purchase price to its value after the accident. Guy Helvering (defendant), the Commissioner of Internal Revenue, reduced Owens’s deduction to $35, the loss of value of the car immediately before and after the accident. The Board of Tax Appeals reversed Helvering and reinstated Owens’s initial loss deduction. The United States Court of Appeals for the Second Circuit affirmed the Board of Tax Appeals. Helvering appealed.
Rule of Law
Issue
Holding and Reasoning (Roberts, J.)
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