Silberman v. Commissioner

Petitioner received income in taxable year from legal sources. In addition to whatever services he performed for such compensation he carried on a business of making and registering bets at licensed race tracks from which he realized no gain. It was illegal in New York to receive and register bets or to assist therein or to allow a person doing the same to occupy a booth at a race track for that purpose. Petitioner paid fees for use of booths and salaries to assistants which he seeks to deduct from income from legal sources as business expense. Held, such expenditures for illegal purposes are…