Sugarland Industries v. Commissioner

*1268OPINION.

Milliken :

Petitioner assigns as error the refusal of the respondent to allow as a deduction, pursuant to section 234(a)(1) of the Revenue Act of 1918, the sum of $100,000 which was contributed in the year 1920 to the Laura Eldridge Hospital Association. Congress, unlike in the case of individuals (section 214), has not allowed as deductions contributions made by corporations, and for the contribution here in question to be allowed as a deduction we must find that the same bore a direct relation, with consequent direct benefits, to the business of petitioner. Section 234 enumerates…