Perkins Bros. v. Commissioner

GARDNER, Circuit Judge.

This is a petition for review of a decision of the Board of Tax Appeals redetermining petitioner’s income tax liability for the taxable years 1928 and 1929 in the respective amounts of $2,131.16 and $1,-■637.51. The deficiencies arise from respondent’s action in eliminating from petitioner’s operating expenditures as claimed in its returns, the amounts of $20,262.07 for 1928, and $13,817.55 for 1929. Respondent determined that these amounts were not deductible as a part of petitioner’s ordinary and necessary operating expenses, upon the ground that they were expended…