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SNOW v. COMMISSIONER

No. 73-641.

416 U.S. 500 (1974)

SNOW ET UX. v. COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided May 13, 1974.

Attorney(s) appearing for the Case

Burgess L. Doan argued the cause and filed briefs for petitioners.

Stuart A. Smith argued the cause for respondent. With him on the brief were Solicitor General Bork, Assistant Attorney General Crampton, Bennet N. Hollander, and Jane M. Edmisten.*

MR. JUSTICE DOUGLAS delivered the opinion of the Court.

Section 174 (a) (1) of the Internal Revenue Code of 1954, 26 U. S. C. § 174 (a) (1), allows a taxpayer to take as a deduction "experimental expenditures which are paid or incurred by him during the taxable year in connection with his trade or business as expenses which are not chargeable to capital account." Petitioner Edwin A. Snow (hereafter petitioner) was disallowed as a deduction his distributive share...

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