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ALLEN INDUSTRIES, INC. v. COMMISSIONER

Docket No. 127-66.

27 T.C.M. 542 (1968)

T.C. Memo. 1968-113

Allen Industries, Inc. v. Commissioner.

United States Tax Court.

Filed June 11, 1968.

Attorney(s) appearing for the Case

Miles Jaffe and Howard K. Schwartz, for the petitioner. Joseph F Dillon, for the respondent.

Memorandum Findings of Fact and Opinion

IRWIN, Judge:

The Commissioner determined deficiencies of $19,066.65 and $9,533.32 in the income tax of petitioner for the taxable years ended December 31, 1959, and December 31, 1960, respectively.

The sole issue for decision is: Whether petitioner is entitled to deduct as an ordinary and necessary business expense under section 162 of the 1954 Code

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