International Trading Co. v. Commissioner of Internal Revenue

STECKLER, District Judge.

This is a petition for review of the decision of the Tax Court of the United States determining deficiencies in the petitioner’s income tax for its taxable years ending August 31, 1951, and August 31, 1952.

The issue before this court is whether the Tax Court erred in disallowing a portion of the maintenance expenses and depreciation claimed by the corporate taxpayer under § 23(a) (1) (A) and (i) (1) and (2) of the Internal Revenue Code of 1939. 1

The Tax Court found and concluded that although certain residential property owned by the corporation at Beaver Lake,…