MONTGOMERY CO. v. COMMISSIONER

Docket No. 4328-67.

54 T.C. 986 (1970)

THE MONTGOMERY CO., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 14, 1970.


Attorney(s) appearing for the Case

D. Paul Alagia, Jr., and J. Bernard Brown, for the petitioner.

W. Gerald Thornton, for the respondent.


BRUCE, Judge:

Respondent determined deficiencies in income tax for the taxable years ended December 31, 1962, 1963, and 1964, of $1,694.62, $4,965.47, and $4,467.65, respectively.

Two issues are presented:

(1) Is a certain "lease cancellation expense" of $10,000 incurred and paid by petitioner in 1962 deductible over a 2-year period as claimed by petitioner, or over a 25-year period as determined by...

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