Fred W. Amend Co. v. Commissioner of Internal Revenue

CASTLE, Senior Circuit Judge.

The petitioner-appellant, Fred W. Amend Co. (hereinafter referred to as taxpayer), prosecutes this appeal from a decision of the Tax Court 1 which sustained the disallowance by the Commissioner of Internal Revenue, respondent-appellee, of deductions in the amounts of $5,500 and $6,200, respectively, claimed by the taxpayer on its income tax returns for its fiscal years ended October 31, 1964, and 1965. The disallowance resulted in. the assessment of income tax deficiencies for those years. The deductions represent payments made by the taxpayer corporation to R. M.…