CURTIS v. COMMISSIONER

Docket No. 104764.

3 T.C. 648 (1944)

JAMES F. CURTIS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 25, 1944.


Attorney(s) appearing for the Case

John P. Ohl, Esq., and Robert C. Brown, Esq., for the petitioner.

James C. Maddox, Esq., for the respondent.


OPINION.

HILL, Judge.

This proceeding involves an income tax deficiency for 1936 in the amount of $93,609.21. Petitioner, an individual, filed his 1936 tax return on the cash receipts and disbursements basis with the collector for the second New York district. The proceeding presents the following questions:

1. Did respondent err in disallowing the deduction of certain expenses allocable to income in respect of which no tax was paid or collectible...

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