DU PONT v. COMMISSIONER

Docket No. 35469.

19 T.C. 377 (1952)

A. RHETT DU PONT AND GERTRUDE DU PONT, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 3, 1952.


Attorney(s) appearing for the Case

William S. Gaud, Jr., Esq., and John N. Stull, Esq., for the petitioners.

Robert R. Blasi, Esq., for the respondent.


Respondent has determined a deficiency in petitioners' income tax for the calendar year 1948 in the amount of $3,680.38. The only adjustment which is contested is explained by respondent as follows:

(1) It is held that the payment of $12,423.37, a portion of its profits, by the partnership of Francis I. du Pont & Company to Paine, Webber, Jackson & Curtis, does not constitute an ordinary and necessary expense of carrying on a trade or business. Hence, the...

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