Anne K. Gossmann, Transferee of Model Farms Dairy v. Seldon R. Glenn, Collector of Internal Revenue

This appeal from the dismissal by the District Court of the taxpayer’s complaint, asserting a claim for refund of taxes based on the disallowance of a claimed deduction as an alleged ordinary and necessary büsiness expense, came on to be heard; and the transcript of record and the oral arguments and briefs of the attorneys for the contending parties have been duly considered;

And it appearing that the findings of fact of the District Court are supported by substantial evidence and are not clearly erroneous, and that the court’s conclusions of law are based upon sound and correct legal…