Commissioner of Internal Revenue v. Wurts-Dundas

(after stating the facts as above).

Section 219 (b) of the Revenue Act of 1921 (42 Stat. 246), so far as now material, provides that the fiduciary shall file the return and that the net income of “the estate or trust” shall be computed in the same manner as that of an individual. By section 212 of the same act (42 Stat. 237), the net incomo of an individual is made the gross income under section-213, less the deductions allowed by section 214. This last-mentioned section allows as deductions, inter alia: “(1) All the ordinary and necessary expenses paid or incurred during the taxable year in…