THERMOCLAD COMPANY v. COMMISSIONER

Docket Nos. 2550-73, 2555-73.

33 T.C.M. 1354 (1974)

T.C. Memo. 1974-289

The Thermoclad Company v. Commissioner. Leon F. Akerly and Rhea Akerly v. Commissioner.

United States Tax Court.

Filed November 14, 1974.


Attorney(s) appearing for the Case

Daniel L.R. Miller, 501 Marine Bank Bldg., Erie, Pa., for the petitioner, The Thermoclad Company. Stephen H. Hutzelman, for the petitioners, Leon F. and Rhea Akerly. David P. Smith, and Stephen R. Takeuchi, for the respondent.


Memorandum Findings of Fact and Opinion

QUEALY, Judge:

The respondent determined deficiencies in the Federal income tax of the Thermoclad Company in the amounts of $16,022 for the taxable year 1969 and $7,076 for the taxable year 1970. Due to concessions by the parties, the only issue remaining for decision in this case is whether the Thermoclad Company is entitled to deduct, as an ordinary and necessary business expense, within the meaning of section 162...

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