"the Fort. Pitt Bedding Company, is no ground upon which to deny the respondent the rieht to deduct these losses, ‘as 4 general rule a corporation and ite steckholders are deemed separate entities and this is true in respect of tax problems, of course, the mule is subject to that the separate identity mey excertional situations present an obstacle to foreenent of puUbLiC or Colonial Ieee Co. v. 54 5, Ot. TES, TOL, Clack, O97; 4i5, Cos v, BG7 JU, Surnet vi 65 Sy Ct. Vs. 6. where Lt otherwise would the due abide or en~ private right. New Eelvering, £99 u, Ss 435, 7e fae Ed, 1648; Burnet v, 410, 838 8B. Ct. 207, 88 y. 3 Petroleum Cir., Process COey except where 'too elose prevent fraud, or ‘when but an agent of another.! stances are present in the obviously Bd. nothing contrary 20 846: Gillis 84 F, court voints not be disre~ a reletionshin tween two or more corporations or @irctmvents public policy,! to Ls YB Cirg, xa 74. Im the last case elted the Out that the corporate entity will garded 7? 442, Comores! th imp, CO,, E87 U. 8 196, wt L, Ed, 899; General Finance Commisotoner, Jenkins the qualification be disregarded in bee offends a statute or 'when necessary one company is None case of at eirewe There is to any these bar, statute nothing or public poliey in the fact that two wer own ell of the stock of two distinet corporations each erieaged in a Ssaparate business, The Board ‘Found that there was no Traud and dn the absence of the other ¢cireunmstunces mentioned above, the mere intention to establish o loss for income tak purposes ean net be held to be fraudulent, or ean either the respondent termed or ea mere the Fort agent for Pitt Bedding the ether Operating concerns, involwed in end Gigtinet lines of business, Company for both be are enatirely separate The respondent @ould have sold and repurehased the securities on the open market and deducted the loss, There is nothing in the eireumstances of this case that rea guires a different rule," 60e@ aiso ! where it a made gale was Be Le page 617 51s, op By ruled that between seffiliates, a sales December LOGE,