Zimmern v. Commissioner of Internal Revenue

BRYAN, Circuit Judge.

This is a petition for review of a decision of the United States Board of Tax Appeals, which refused to allow a deduction claimed by petitioner in his return of income taxes for the year 1920, on account of an expenditure of $20,697.55 in repairing damages caused by the sinking of a barge used in connection with petitioner’s coal business. The barge sank in Mobile Harbor in 1918 during a storm, and was raised and repaired in 1920. Petitioner employed D. G. Hodges to do the repair work. That part of the Board’s findings of fact which is material here reads •as follows:

“The…