Appeal of Pan-American Hide Co.

*1250OPINION.

Sternhagen:

The taxpayer’s contention in effect is that it may take from its income in one pocket an amount equal to what it would have to pay as fidelity insurance premiums and put this in another pocket as a reserve and deduct it from gross income as an ordinary and necessary expense incurred in its business. The contention is similar to that which was rejected by the Board in Ostheimer's Appeal, 1 B. T. A. 18; Appeal of Consolidated, Asphalt Co., 1 B. T. A. 79; and Appeal of Uvalde Co., 1 B. T. A. 932. The Appeal of Charles A. Collin, 1 B. T. A. 305, cited by the taxpayer, is not in…