Bloomfield Steamship Co. v. Commissioner

OPINION.

Black, Judge;

The first issue here presented arises under section

23(a) (1) (A) of the 1939 Code.1 Petitioner contends that the expenditures made to repair the vessels it purchased from the Maritime Administration, so as to place the vessels in class, that is, in seaworthy and cargoworthy condition, are deductible as ordinary and necessary business expenses. The respondent contends that deduction of these expenses as ordinary and necessary business expenses is banned by section 24(a) (2) of the 1939 Code.2 Regulations 111, section 29.23 (a)-4,3 define repairs, the cost of which is…