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HORTON v. COMMISSIONER

Docket Nos. 4206, 8534.

5 T.C.M. 526 (1946)

Hiram T. Horton v. Commissioner.

United States Tax Court.

Entered June 26, 1946.

Attorney(s) appearing for the Case

Dana Latham, Esq. and Austin H. Peck, Jr., Esq., 1112 Title Guarantee Bldg., 411 West Fifth St., Los Angeles 13, Calif., for the petitioner. B. M. Coon, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

HARLAN, Judge:

This matter is before this court to procure redetermination of deficiencies declared by the Commissioner for the years 1940 and 1941 in the respective amounts of $8,571,16 and $4,022.64. The deficiencies were occasioned by the refusal of the Commissioner to permit the taxpayer to deduct percentages of net profit paid by the taxpayer to the owner of a mining...

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