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ST. PETERSBURG BANK & TRUST COMPANY v. UNITED STATES

Civ. No. 71-425.

362 F.Supp. 674 (1973)

ST. PETERSBURG BANK & TRUST COMPANY, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, M. D. Florida. Tampa Division.

August 27, 1973.

Attorney(s) appearing for the Case

Michel G. Emmanuel, Michael D. Annis, of Carlton, Fields, Ward, Emmanuel, Smith & Cutler, Tampa, Fla., for plaintiff.

Scott P. Crampton, Asst. Atty. Gen., Jerome Fink, Daniel C. Perri, Attys., Dept. of Justice, Washington, D. C., for defendant.

OPINION

HODGES, District Judge.

St. Petersburg Bank & Trust Company (the Bank) instituted this suit pursuant to 28 U.S.C.A. § 1346(a)(1) for the recovery of income taxes paid by it as a result of a deficiency assessment made by the Commissioner of Internal Revenue for the tax years 1965 and 1966. The issue is the propriety of certain deductions made by the Bank for entertainment expenses during those years. The governing provisions of the Code are...

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