Higgins v. Commissioner

Petitioner, the taxpayer, with extensive investments in real estate, bonds and stocks, devoted a considerable portion of his time to the oversight of his interests and hired others to assist him in offices rented for that purpose. For the tax years in question, 1932 and 1933, he claimed the salaries and expenses incident to looking after his properties were deductible under § 23 (a) of the Revenue Act of 1932. The Commissioner refused the deductions. The applicable phrases are: “In computing net income there shall be allowed as deductions: (a) Expenses. — All the ordinary and necessary…