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AMFAC, INC. v. C. I. R.

No. 78-2918.

626 F.2d 109 (1980)

AMFAC, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided August 21, 1980.

Attorney(s) appearing for the Case

Richard L. Griffith, Cades, Schutte, Fleming & Wright, Honolulu, Hawaii, for petitioner-appellant.

Gayle P. Miller, Washington, D.C., argued, Libero Marinelli, Jr., Washington, D.C., on brief, for respondent-appellee.

Before TRASK and CHOY, Circuit Judges, and SMITH, District Judge.

RUSSELL E. SMITH, District Judge:

The sole question in this case is whether certain expenditures made by Puna Sugar Co., Ltd. (Puna), a subsidiary of the petitioner, Amfac, Inc., are deductible under Section 175(a) of the Internal Revenue Code (26 U.S.C. § 175(a)). The Tax Court held an evidentiary hearing, made findings of fact, and concluded that the expenses were not deductible. We affirm.

The record shows that Puna has been growing sugar cane on the...

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