Daniel Bros. Co. v. Commissioner of Internal Revenue

WALKER, Circuit Judge.

The Board of Tax Appeals decided against a contention of petitioner, a Georgia corporation, that in the determination of its taxable income for the fiscal years ending August 31, 1920, and August 31,1921, it was entitled to deductions on account of interest paid by reason of payments it made during those years under a contract the pertinent provisions of which, and petitioner’s payments thereunder, were stated as follows in the Board’s finding of facts:

“On June 1, 1920, the petitioner entered into written contract with Mrs. Josephine I. ■Richardson, to purchase from her…