Peto v. Commissioner of Internal Revenue

Second Circuit

Peto v. Commissioner of Internal Revenue

262 F.2d 342

CourtCourt of Appeals for the Second Circuit

DecidedDecember 31, 1958

DocketNo. 159, Docket 25225

StatusPublished

Cited by1 cases

This text of 262 F.2d 342 (Peto v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Peto v. Commissioner of Internal Revenue, 262 F.2d 342 (2d Cir. 1958).

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Opinion

PER CURIAM.

We agree thoroughly with Judge Mur-dock’s findings of fact and opinion that the losses in these ill-fated ventures cannot be considered “ordinary and necessary expenses paid * * * in carrying on any trade or business” under I.R.C. 1939, § 23(a) (1) (A). Nor do we find basis for sustaining the taxpayers’ belated claim that the losses were “ordinary and necessary expenses * * * for the production or collection of income” under I.R.C.1939, § 23(a) (2).

Decision affirmed.

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PER CURIAM.

We agree thoroughly with Judge Mur-dock’s findings of fact and opinion that the losses in these ill-fated ventures cannot be considered “ordinary and necessary expenses paid * * * in carrying on any trade or business” under I.R.C. 1939, § 23(a) (1) (A). Nor do we find basis for sustaining the taxpayers’ belated claim that the losses were “ordinary and necessary expenses * * * for the production or collection of income” under I.R.C.1939, § 23(a) (2).

Decision affirmed.

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262 F.2d 342, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peto-v-commissioner-of-internal-revenue-ca2-1958.

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