Haft v. Commissioner

OPINION

Rattm, Judge:

The Commissioner’s disallowance of deductions for expenses aggregating $11,670.61 in 1958 raises two principal issues: Whether petitioner was engaged in business in 1958, and, if so, whether the challenged expenditures were proximate! y related thereto. The fact that the expenditures were made is not in dispute.

1. Petitioner has spent virtually his entire adult life in the costume jewelry business, and during the period 1932-56 he served as a salesman for Coro, Inc. He worked primarily on a commission basis, earning as much as $60,000 a year, and paying his own expenses.…