Kanne v. American Factors, Limited. American Factors, Limited v. Kanne

DENMAN, Chief Judge.

The taxpayer, American Factors, Limited, appeals from a judgment of the United States District Court, District of Hawaii, rendered upon a complaint for a refund of taxes claimed to be overpaid for the tax year 1932. The complaint alleges that the Commissioner of Internal Revenue had erred in disallowing a deduction made in the taxpayer’s return for that year of $568,607.76, as an ordinary and necessary business expense. This sum had been paid by it in that and prior years in the defense of litigation, hereafter called the “Hack-feld litigation,” brought against it and 23…