A. L. Greer and Ruth E. Greer v. Commissioner of Internal Revenue

BELL, Circuit Judge:

This matter arises out of a petition to review a Tax Court decision upholding deficiency assessments. 1 The question presented turns on whether business expenses, admittedly deductible, accrued to petitioners as losses from a joint venture, or to a corporation, Oscura Company, Inc., the wholly owned subsidiary •of another corporation, United Minerals, Inc., in which petitioners and their fellow venturers were the sole stockholders.

It is undisputed that the expenses were incurred by the subsidiary, Oscura Company, Inc., in the development and operation of a lead mine in…