Marjorie M. P. May v. Commissioner of Internal Revenue

ALBERT V. BRYAN, Circuit Judge.

Yacht Sea Cloud when decommissioned, abandoned for personal use and' held for sale became, says her owner, taxpayer Marjorie M. P. May, “property held for the production of income”. 1 Thereafter, she contends, the yearly cost, of conservation, maintenance and depreciation of the barque were proper deductions allowable in the computation of her Federal income taxes. While conceding that the law permits such deductions even on non-business properties, the Commissioner disallowed her claims because he-concluded they did not meet the prescription of the statute.…