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UNION BAG-CAMP PAPER CORPORATION v. UNITED STATES

Nos. 147-64 to 150-64.

366 F.2d 1011 (1966)

UNION BAG-CAMP PAPER CORPORATION v. The UNITED STATES.

United States Court of Claims.

October 14, 1966.

Attorney(s) appearing for the Case

Arthur M. Becker, New York City, for plaintiff, John H. Alexander, New York City, attorney of record, William B. Landis, Joseph E. Bachelder III, and Nixon, Mudge, Rose, Guthrie & Alexander, New York City, of counsel.

Edward B. Greensfelder, Jr., Washington, D. C., with whom was Asst. Atty. Gen. Mitchell Rogovin, for defendant, Lyle M. Turner and Theodore D. Peyser, Jr., Washington, D. C., of counsel.

Before COWEN, Chief Judge, and LARAMORE, DURFEE, DAVIS and COLLINS, Judges.

COWEN, Chief Judge.

Plaintiff deducted as ordinary and necessary business expenses (1) annual payments made by it under various leases for the exclusive use of timberlands, and (2) a portion of its expenses in managing these wooded tracts. The Internal Revenue Service disallowed the deductions, treating the yearly rentals as capital expenditures forming a part of the acquisition cost of timber and the management expenses as amounts allocable to the cost of timber...

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