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Leonard A. PETO and Vera Peto (Husband and Wife), Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee

United States Court of Appeals for the Second Circuit1958-12-31No. No. 159, Docket 25225
262 F.2d 342

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

PER CURIAM.

We agree thoroughly with Judge Mur-dock’s findings of fact and opinion that the losses in these ill-fated ventures cannot be considered “ordinary and necessary expenses paid * * * in carrying on any trade or business” under I.R.C. 1939, § 23(a) (1) (A). Nor do we find basis for sustaining the taxpayers’ belated claim that the losses were “ordinary and necessary expenses * * * for the production or collection of income” under I.R.C.1939, § 23(a) (2).

Decision affirmed.