Before JAMES, SMITH, and TRUSSELL.
This is an appeal from the determination of a deficiency in income and profits taxes for the year 1919 amounting to $846.86, a portion of which is not in issue.
FINDINGS OF FACT.
The taxpayer is a New York corporation located in New York City.
During the year 1919 the taxpayer sold certain factory property acquired in the year 1912. The sales price was $20,500. The cost of the property to and including the date of sale and the value on March 1, 1913, was $28,000.
The taxpayer claimed a loss on account of said sale of $7,500. The Commissioner reduced that amount of loss by $3,689, alleged t0 be depreciation upon improvements for the period between the acquisition of the property and the date of sale.
DECISION.
The determination of the Commissioner is approved. .