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PAGE v. C. I. R.

No. 74-2990.

524 F.2d 1149 (1975)

George PAGE, Transferee, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Ninth Circuit.

September 19, 1975.

Attorney(s) appearing for the Case

Steven W. Phillips, Willis, Butler & Scheifly, Los Angeles, Cal., for appellant.

Scott P. Crampton, Asst. Atty. Gen., Tax Div., Gilbert E. Andrews, Chief, App. Section, Elmer J. Kelsey and Carolyn R. Just, Tax Div., U. S. Dept. of Justice, for appellee.

Before ELY and CARTER, Circuit Judges, and EAST, District Judge.

OPINION

PER CURIAM:

Three corporations, of whose assets Page is the transferee, entered into complete liquidations under 26 U.S.C. § 337. The corporations incurred brokerage commission expenses in connection with sales of certain real estate. The real estate had been held by the corporations as capital assets. The corporations deducted the brokerage commissions against ordinary income as ordinary and necessary...

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