Warren Burnett and Emma Burnett v. Commissioner of Internal Revenue

MOORE, Circuit Judge:

This is a petition to review a decision of the Tax Court, 42 T.C. 9 (1964), affirming the assessment of federal income tax deficiencies for the year 1961 against petitioners Warren and Emma Burnett, husband and wife, 1 (hereinafter referred to singularly as petitioner), which resulted from the disallowance of deductions, totalling $50,417.18, claimed as business expenses under Section 162 (a) of the Internal Revenue Code of 1954, 26 U.S.C. § 162(a).

Petitioner is an attorney in Odessa, Texas, whose practice is primarily devoted to representing plaintiffs in workmen’s…