Holdcroft Transp. Co. v. Commissioner of Internal Revenue

SANBORN, Circuit Judge.

The petitioner asserts that the Commissioner of Internal Revenue and the Tax Court of the United States erroneously disallowed a deduction taken by petitioner in its income and excess-profits tax return for the fiscal year ended October 31, 1940. The disallowance caused a deficiency of $1,017.85 in petitioner’s income tax and $314.19 in its declared value excess-profits tax for that year.

The question presented is whether the deduction claimed by petitioner was for capital expenditures, which were nondeductible, or for ordinary and necessary business expenses or…