First National Bank in St. Louis v. Commissioner

*1128OPINION.

McMahon:

The sole question for decisipn here is whether the respondent erred in disallowing as a deduction in each of the years 1927 and 1928 the amount of $5,200 contributed in each of those years by the petitioner to the Industrial Club of St. Louis.

Section 234 of the Revenue Act of 1926 and section 23 of the Revenue Act of 1928 allow as deductions all the ordinary and necessary expenses paid or incurred by a corporation during the taxable year in carrying on any trade or business.

The evidence discloses that the Industrial Club of St. Louis was organized for the purpose of advancing…