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ARWELL, INC. v. COMMISSIONER

Docket No. 47549.

13 T.C.M. 829 (1954)

T. C. Memo. 1954-136

Arwell, Inc. v. Commissioner.

United States Tax Court.

Filed August 24, 1954.

Attorney(s) appearing for the Case

C. C. Chapelle, Esq., Alden, Mich., for the petitioner. Edward L. Newberger, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency of $2,207.78 in the income tax of the petitioner for 1949. The only issue for decision is whether the petitioner is entitled to deduct $22,500 as an ordinary and necessary expense of its business or as "cost of operations".

Findings of Fact

The petitioner filed its return for 1949 with the collector of internal revenue for

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