
    Appeal of STAR SPORTING GOODS CO.
    Docket No. 1832.
    Submitted April 21, 1925;
    decided May 27, 1925.
    
      W. Frank Gibbs, Esq., for the Commissioner.
    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 to 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. Appeal of Even Realty Co., 1 B. T. A. 355.  