UNITED FINANCE AND THRIFT CORPORATION OF TULSA, Formerly the State Loan Company of Tulsa, and United Finance and Thrift Corporation of Tulsa County, Formerly The State Loan Company, (Oklahoma), Petitioners,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent.
United States Court of Appeals Fourth Circuit.https://leagle.com/images/logo.png
Argued June 7, 1960.
Decided September 29, 1960.
Attorney(s) appearing for the Case
Robert Ash, Washington, D. C., (Ash, Bauersfeld & Burton, Washington, D. C., on brief), for petitioners.
John J. Pajak, Attorney, Department of Justice, Washington, D. C., (Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson and Harry Baum, Attorneys, Department of Justice, Washington, D. C., on brief), for respondent.
Before SOPER and HAYNSWORTH, Circuit Judges, and CHARLES F. PAUL, District Judge.
United States Court of Appeals Fourth Circuit.
CHARLES F. PAUL, District Judge.
These are consolidated petitions for review of decisions of the Tax Court1 disallowing, in part, deductions claimed by the taxpayers on account of depreciation. The taxpayers claimed in the Tax Court, and here insist, that they are entitled to deductions as "new business development expense" of the full amounts of sums which they say were paid solely as consideration for "covenants not to compete" obtained...
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