United Draperies, Inc. v. Commissioner of Internal Revenue

CASTLE, Circuit Judge.

These petitions for review of Tax Court decisions concern income tax deficiencies determined against petitioner as the result of the disallowance of certain deductions claimed for the taxable years involved1 as commission expenses and sales promotion expenses paid and incurred by the petitioner in carrying on its business. The claimed commission expenses disallowed total $138,423.61, and the claimed sales promotion expenses disallowed total $21,432.55.

During the years in issue (1957-1960), petitioner was engaged primarily in the manufacture and sale of draperies to…