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DRISKILL HOTEL COMPANY v. COMMISSIONER

Docket No. 31562.

12 T.C.M. 565 (1953)

Driskill Hotel Company v. Commissioner.

United States Tax Court.

Entered May 22, 1953.

Attorney(s) appearing for the Case

Ben H. Powell, Jr., Esq., 702 Brown Building, P. O. Box 63, Austin, Tex., and W. Morgan Hunter, Esq., for the petitioner. John P. Higgins, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

JOHNSON, Judge:

Respondent determined a deficiency in petitioner's income tax for the year 1946 in the amount of $5,320.

The only issue for decision is whether the payment of $14,000 by petitioner to its manager in his dismissal and termination of employment is deductible as an ordinary and necessary business expense under section 23 (a) of the Internal Revenue Code.

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