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INTERNATIONAL F. CORP. v. COMMISSIONER OF INT. REV.

No. 5.

135 F.2d 310 (1943)

INTERNATIONAL FREIGHTING CORPORATION, INC., v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

March 6, 1943.

Attorney(s) appearing for the Case

Paul E. Shorb, and Marion P. Wormhoudt, both of Washington, D. C., and David C. Moore, of Wilmington, Del. (Covington, Burling, Rublee, Acheson & Shorb, of Washington, D. C., of counsel), for petitioner.

Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and Warren F. Wattles, Sp. Assts. to the Atty. Gen., for respondent.

Before L. HAND, CHASE and FRANK, Circuit Judges.

FRANK, Circuit Judge.

1. Up to the time in 1936 when the shares were delivered to the employees, the taxpayer retained such control of the shares that title had not passed to the employees.1 We think the Tax Court correctly held that the market value at the time of delivery was properly deducted by the taxpayer as an ordinary expense of the business under Revenue Act 1936, § 23(a), 26 U.S.C.A. Int.Rev.Code § 23(a), because that...

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