Thrift Realty Co. v. Commissioner

OPINION.

Leech :

Petitioner here contests a deficiency of $3,482.25 in income tax for the year 1922 and $174.11 representing a 5 percent negligence penalty as provided by section 250 (e) of the Revenue Act of 1921.

The deficiency arises by reason of the disallowance of certain deductions representing business expenses and amortization upon a leasehold and from an increase of petitioner’s income by $31,975.45 *546as representing profit from the sale of certain real estate in the taxable year.

By the proceeding petitioner puts in issue the action of respondent in respect to each disallowance of a…