Miller v. Commissioner
United States Board of Tax Appeals
DEDUCTIONS - ORDINARY AND NECESSARY BUSINESS EXPENSES. - In 1933 an insurance company, represented by petitioner as local and general agent, went into receivership. Thereupon petitioner canceled all policies of his customers written by the insolvent company, and reinsured them in another company.
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DEDUCTIONS - ORDINARY AND NECESSARY BUSINESS EXPENSES. - In 1933 an insurance company, represented by petitioner as local and general agent, went into receivership. Thereupon petitioner canceled all policies of his customers written by the insolvent company, and reinsured them in another company. In order to protect and promote his own business, petitioner voluntarily paid certain claims of his customers then matured under policies of the insolvent company, and also paid the premiums on the reinsurance. On the facts, held, such expenditures constitute allowable deductions as ordinary and…
1Opinion of the Court
OPINION.
Hill :
This proceeding is for the redetermination of a deficiency in petitioner’s income tax as determined by respondent for the year 1933 in the amount of $3,857.85. The amended pleadings raise the following issues: (1) Whether or not respondent erred in holding that petitioner’s salary of $5,000 as president of the board of water works of the city of Louisville is not exempt from Federal taxation; (2) whether or not respondent erred in not allowing as a deduction from income interest paid on borrowed money in the amount of $242.91; (3), (4), and (5), whether or not respondent erred…
2Cases cited2 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Washburn v. National Wall-Paper Co.Court of Appeals for the Second Circuit · 1897
3Cited by25 opinions
- Pepper v. CommissionerUnited States Tax Court · 1961
- Horne v. CommissionerUnited States Tax Court · 1972
- United States v. E. L. Bruce Co., IncCourt of Appeals for the Sixth Circuit · 1950
- Lettie Pate Whitehead Foundation, Inc., Cross-Appellant v. United States of America, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1979
- Lots, Inc. v. CommissionerUnited States Tax Court · 1968
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