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ROSENBAUM v. COMMISSIONER

Docket Nos. 21840, 21841.

16 T.C. 664 (1951)

GEORGE D. ROSENBAUM, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ALFRED LOUIS STAMM, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 29, 1951.

Attorney(s) appearing for the Case

Bernard Wall, Esq., and Irving T. Palmer, C. P. A., for the petitioners.

Thomas R. Charshee, Esq., for the respondent.

Respondent has determined deficiencies in the income tax of petitioners Rosenbaum and Stamm in the sums of $12,798.75 and $24,810.63, respectively, for the taxable year 1944.

The issue is whether the petitioners may deduct from their 1944 taxable income the sums of $13,317.41 and $26,634.81, respectively, as "expenses" within the meaning of section 23 (a) (1) (A) or section 23 (a) (2) of the Internal Revenue Code; or as a "loss" within the meaning of section 23 (e...

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