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LEVIN v. COMMISSIONER OF INTERNAL REVENUE

Nos. 11425 and 11426.

219 F.2d 588 (1955)

Harry M. LEVIN and Freda H. Levin, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Third Circuit.

Decided February 11, 1955.

Attorney(s) appearing for the Case

Benjamin F. Kivnik, Philadelphia, for petitioners.

Grant W. Wiprud, Sp. Asst. to the Atty. Gen. (H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Robert N. Anderson, Sp. Assts. to the Atty. Gen., on the brief), for respondent.

Before MARIS, GOODRICH, and STALEY, Circuit Judges.

STALEY, Circuit Judge.

Taxpayers object to the disallowance of a business deduction taken in 1946 which represented a liability for future advertising services under a contract entered into in December of that year.

During 1946 taxpayers were partners engaged in manufacturing and selling food products. On December 12, 1946, the partnership entered into a contract providing for the display of cards advertising its...

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