HENRY WATTERSON HOTEL CO. v. COMMISSIONER

Docket No. 19926.

15 T.C. 902 (1950)

HENRY WATTERSON HOTEL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 19, 1950.


Attorney(s) appearing for the Case

P. M. Harris, Esq., for the petitioner.

J. O. Durkan, Esq., for the respondent.


OPINION.

RICE, Judge:

Respondent determined a deficiency of $8,600.33 in petitioner's excess profits tax for the calendar year 1945. The sole issue is whether a payment to the United States on March 2, 1945, for O. P. A. violations is an ordinary and necessary business expense entitled to deduction under section 23 (a) (1) (A) of the Internal Revenue Code. All of the facts have been stipulated, are so found, and are incorporated herein.

Petitioner...

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