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HOTEL SULGRAVE, INC. v. COMMISSIONER

Docket No. 41449.

21 T.C. 619 (1954)

HOTEL SULGRAVE, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated January 29, 1954.

Attorney(s) appearing for the Case

Paul V. Wolfe, Esq., for the petitioner.

George E. Grimball, Jr., Esq., for the respondent.

The respondent determined a deficiency in the income tax of the petitioner in the amount of $2,419.32 for the fiscal year ended June 30, 1948.

The sole issue is whether the petitioner is entitled to deduct as an ordinary and necessary business expense all or any part of the cost of installing a sprinkler system in a building owned by it.

FINDINGS OF FACT.

The petitioner, a corporation organized in 1945 under...

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