McAdams v. Commissioner of Internal Revenue

*55HUTCHESON, Chief Judge.

The Commissioner determined and the Tax Court held that petitioners were not entitled to deduct in taxable years 1944 and 1945 moneys repaid their co-owner in those years in reimbursement of their pro rata shares of drilling and development expenses incurred and paid for them by Luse, their co-owner in 1941.

Taxpayers, aggrieved by the decision,1 petitioned for review, and are here insisting that what occurred in 1941 was not a payment by their co-owner, the brother and brother-in-law of taxpayers, of the whole of the debt on his and their account, but a payment by the…