Glasgow Village Development Corp. v. Commissioner

OPINION.

Black, Judge:

The first issue is whether Glasgow may deduct as ordinary and necessary business expenses under section 162 of the 1954 Code1 payments made to Carpenter in each of the years 1954, 1955, and 1956 in the annual amount of $12,499.76. As a corollary to this issue is the question whether such payments by Glasgow constitute distributions taxable as dividends to the individual petitioners in the years 1955 and 1956. The only 2 years which we have before us insofar as the individual petitioners are concerned are 1955 and 1956; we do not have the year 1954 before us as to the…