Thal v. Commissioner of Internal Revenue‪.‬

Petitioner during the year 1929 purchased an aggregate of 700 shares of the capital stock of the United Founders Corporation at a total cost of $39,900.98 for which, in a subsequent tax free exchange, he received 70 shares of the capital stock of the American General Corporation. In 1939, petitioner sold these shares for $259.10, sustaining a loss of $39,641.88.