WELCH v. COMMISSIONER OF INTERNAL REVENUE

No. 9585.

63 F.2d 976 (1933)

WELCH v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Eighth Circuit.

March 24, 1933.


Attorney(s) appearing for the Case

Alexander E. Horn, of St. Paul, Minn. (Thomas D. O'Brien and Edward S. Stringer, both of St. Paul, Minn., on the brief), for petitioner.

J. P. Jackson, Sp. Asst. to Atty. Gen. (G. A. Youngquist, Asst. Atty. Gen., Sewall Key, Sp. Asst. to Atty. Gen., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Hugh Brewster, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief), for respondent.

Before STONE, VAN VALKENBURGH, and BOOTH, Circuit Judges.


STONE, Circuit Judge.

This is a petition to review a decision of the Board of Tax Appeals, affirming an assertation by the Commissioner of deficiencies in the income taxes of this petitioner for the years 1924 to 1928, inclusive.

The deficiencies are properly asserted unless the income for the involved years is to be reduced by certain payments which the taxpayer contends are properly deductible business expenses. The character of these payments is as follows...

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