George H. And Sarah Newi v. Commissioner of Internal Revenue

MOORE, Circuit Judge:

The Commissioner of Internal Revenue (the Commissioner) appeals from that portion of the decision of the Tax Court which holds that “the petitioners were entitled to an ordinary and necessary business expense deduction for a portion of the rent, light and cleaning of their apartment.” The petitioners below, George H. Newi (hereinafter referred to as the Taxpayer) and Sarah Newi, are husband and wife. George H. Newi, during the year in question 1964, for which a joint return was filed, was “an outside salesman of television time for the American Broadcasting Company…