TANK TRUCK RENTALS, INC. v. COMMISSIONER

Docket No. 51051.

26 T.C. 427 (1956)

TANK TRUCK RENTALS, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 31, 1956.


Attorney(s) appearing for the Case

Leonard Sarner, Esq., for the petitioner.

John D. Armstrong, Esq., for the respondent.


The respondent determined a deficiency in income tax of petitioner for the year 1951 in the amount of $12,172.34.

The principal issue is whether fines paid by petitioner in 1951 for violating motor vehicle weight limitation laws of certain States are deductible as ordinary and necessary business expenses under the provisions of section 23 (a) (1) (A) of the Internal Revenue Code of 1939.

FINDINGS OF FACT.

A portion of the facts have been stipulated...

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