Millinery Center Building Corp. v. Commissioner

This case involves an interpretation of § 23 (a)(1)(A) of the Internal Revenue Code of 1939, as amended, 26 U. S. C. § 23 (a) (1) (A), providing for the deduction from gross income, in computing net income, of all the “ordinary and necessary expenses paid or incurred . . . in carrying on any trade or business . . . .” The Commissioner determined a deficiency in petitioner’s excess-profits tax for 1945; petitioner sought a redetermination of its liability in the Tax Court, which made the following findings of fact. In April 1924, petitioner leased land in New York City for 21 years, with an…