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PETO v. COMMISSIONER

Docket No. 57440.

17 T.C.M. 139 (1958)

T.C. Memo. 1958-34

Leonard A. Peto and Vera Peto v. Commissioner.

United States Tax Court.

Filed February 28, 1958.

Attorney(s) appearing for the Case

John Wattawa, Esq., 1317 F Street Northwest, Washington, D. C., for the petitioners. Thomas C. Tyre, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency of $15,083.85 in income tax for 1948. The issues for decision are whether the petitioners are entitled to deduct as ordinary and necessary business expense (a) $4,199.60 expended by Leonard in 1948 in an unsuccessful effort to have Montreal install a monorailway system which might lead to employment of Leonard in some capacity, and (b) $29,353.14 expended by Leonard in 1948 in an unsuccessful...

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