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MUNROE LAND COMPANY v. COMMISSIONER

Docket No. 3720-64.

25 T.C.M. 3 (1966)

T.C. Memo. 1966-2

Munroe Land Company v. Commissioner.

United States Tax Court.

Filed January 4, 1966.

Attorney(s) appearing for the Case

James C. Herndon, 430 Second National Bldg., Akron, Ohio, for the petitioner. Alan E. Cobb, for the respondent.

Memorandum Findings of Fact and Opinion

HARRON, Judge:

The Commissioner determined a deficiency in income tax for the taxable year 1962 in the amount of $3,801.32. The main question is whether the nature of an expenditure in 1962, relating to fixing the roof of a building owned by petitioner, was for repairs, the cost of which was a deductible business expense under section 162, 1954 Code, or was a capital expenditure.

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