United Profit-Sharing Corp. v. United States

The plaintiff was organized in July, 1914, to engage in the business of selling redeemable coupons and certificates to widely known business concerns, for distribution by them with sales of their products. During the years 1914, 1915, and 1916 plaintiff expended large sums of money in advertising its business throughout the country for the purpose of procuring desirable contracts with large manufacturers and merchants. In its income-tax returns for 1914, 1915, and 1916 plaintiff claimed as deductions from gross income the expenses of said advertising campaign, as “ ordinary and necessary…