Carl Reimers Co., Inc. v. Commissioner of Internal Revenue

CHASE, Chief Judge.

The petitioner, Carl Reimers Co., Inc., seeks reversal of a decision of the Tax Court disallowing a deduction under § 23(a)(1)(A) of the Internal Revenue Code, 26 U.S.C.A. § 23(a)(1)(A), of a payment of $4,590.83 which it claims was an ordinary and necessary business expense incurred in its fiscal year ending March 31, 1947. It is a New York corporation, organized in 1946 by Carl and Peg Reimers, each of whom own fifty per cent of its stock. It operates an advertising agency which derives its income from the placement for its clients of advertising in newspapers and…