Commissioner of Internal Rev. v. Continental Screen Co.

HICKS, Circuit Judge.

Petition by tbe Commissioner of Internal Revenue to review a decision of the Board of Tax Appeals reversing the action of the commissioner in assessing a deficiency in income taxes against respondent in the sum of $7,-224.99 for the year 1925 and for the period from January 1 to July 31 of the year 1926. These deficiencies arose from a disallowance by the commissioner of $40,000 and $15,000 which respondent had paid in the years 1925 and 1926, respectively, as attorney fees.

Whether these fees were allowable as deductions depends of course upon whether they were paid as…