CAPITOL INDEMNITY INSURANCE COMPANY v. COMMISSIONER

Docket No. 50803.

25 T.C. 147 (1955)

CAPITOL INDEMNITY INSURANCE COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 28, 1955.


Attorney(s) appearing for the Case

Byron Emswiller, Esq., for the petitioner.

John L. Carey, Esq., for the respondent.


OPINION.

RAUM, Judge:

Respondent has determined a deficiency in the income tax of petitioner for the calendar year 1949 in the amount of $5,104.24. A number of issues have been conceded, and the sole question left for our determination is whether a payment of $5,966.26 made by the petitioner in 1949 is deductible as an ordinary and necessary business expense, pursuant to section 23 (a) of the Internal Revenue...

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