George Page, Transferee v. Commissioner of Internal Revenue

OPINION

Before ELY and CARTER, Circuit Judges, and EAST, * District Judge. PER CURIAM:

Three corporations, of whose assets Page is the transferee, entered into complete liquidations under 26 U.S.C. § 337. The corporations incurred brokerage commission expenses in connection with sales of certain real estate. The real estate had been held by the corporations as capital assets. The corporations deducted the brokerage commissions against ordinary income as ordinary and necessary business expenses under 26 U.S.C. § 162. The Commissioner disallowed these expenses, holding that the expenses should be…