Powell v. Commissioner of Internal Revenue

BINGHAM, Circuit Judge.

This is a petition to review an order or decision of the Board of Tax Appeals. The Commissioner determined a deficiency of $8,882.12 in the petitioner’s income tax return for the year 1930. In determining the deficiency, the Commissioner passed upon two questions: First, was the sum of $9,-442.38, which the petitioner spent for traveling expenses, expended in connection with a trade or business regularly carried on by him? The Commissioner disallowed it as a deduction in determining the deficiency; but before the Board of Tax Appeals he conceded that traveling expenses…