—"a loss may become complete enough for deduction without the taxpayer's establishing that there is no possibility of an eventual recoupment."

In establishing the date of worthlessness, the taxpayer is aided by the rule that the date is to be fixed by "identifiable events" which form the basis of reasonable grounds for abandoning any hope for the future.

Welch, 1 Cir., 140 F. 2d 271, 273, and "The taxing act does not require the taxpayer to be an incorrigible optimist."

They do not charge for appreciation of property or allow a loss from a fall in market value unless realized in money by a sale.

"The case turns upon the question whether the loss, concededly sustained by the respondent through the seizure of the assets of the German company in 1918, was so evidenced by a closed transaction within the meaning of the quoted statute and treasury regulations as to authorize its deduction from gross income of that year. The statute obviously does not …

In our opinion the appointment of the receiver for the corporation was the "identifiable event" which fixed the loss as one of the year 1930.

—defined what the statute does contemplate: "The deduction from gross income of losses, which are fixed by identifiable events, such as the sale of property (article 141, 144), or caused by its destruction or physical injury (article 141, 142, 143), or, in the case of debts, by the occurrence of such events as prevent their collection (article 151)

"The statute obviously does not contemplate and the regulations*** forbid the deduction of losses resulting from the mere fluctuation in value of property owned by the taxpayer."

—it appears that during the war the German government sequestered the property of a German corporation which, through ownership of all its capital stock, was controlled by an American corporation.

Before a loss may be claimed as a deduction, it must be evidenced by a closed or completed transaction.