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BERWIND v. COMMISSIONER

Docket No. 8599.

8 T.C. 1112 (1947)

CHARLES G. BERWIND, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 26, 1947.

Attorney(s) appearing for the Case

Kenneth W. Gemmill, Esq., for the petitioner.

Robert H. Kinderman, Esq., for the respondent.

Respondent determined a deficiency of $11,446.68 in petitioner's income tax for 1940 in part by disallowing the deduction of an amount paid under a contract to a corporation which had advanced funds to a trust company of which petitioner was a director and shareholder. Petitioner assails the disallowance and also claims a deduction of the profits of a trust fund created to repay the advance, which profits had been taxed to him in...

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