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BORGMANN v. C. I. R.

No. 24911.

438 F.2d 1211 (1971)

Raymond F. BORGMANN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Ninth Circuit.

February 24, 1971.

Attorney(s) appearing for the Case

George Bouchard (argued), Laguna Hills, Cal., for petitioner.

Janet Spragens (argued), Atty., Dept. of Justice, Johnnie Walters, Asst. Atty. Gen., Tax Div., K. Martin Worthy, Chief Counsel, Washington, D. C., for respondent.

Before TUTTLE, ELY, and KILKENNY, Circuit Judges.

PER CURIAM:

For the taxable year 1964, Borgmann sought to deduct a large part of the salary paid, as well as a portion of the cost of room and board furnished, to an employee residing in his home. The deduction was claimed as a medical expense under Sections 213(a) and 213(e) (1) of the Internal Revenue Code of 1954, 26 U.S.C. §§ 213(a), 213(e) (1).1 The Commissioner disallowed all...

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