L. A. Thompson Scenic Railway Co. v. Commissioner

*1205OPINION.

MoeRis:

The first allegation of error urged by the petitioner is with respect to the deductibility of amounts set aside out of its income in 1920 and 1921 for self insurance. This issue was submitted by the petitioner for consideration on the record made in the Appeal of L. A. Thompson Scenic Railway, 2 B. T. A. 665, wherein the identical issue was raised and it was decided that the amounts set aside in a reserve for self insurance do not constitute ordinary and necessary business expenses within the meaning of the taxing statutes. That decision is controlling in the instant…