U.S. Court of Appeals for the Second Circuit, 1958

Peto v. Commissioner of Internal Revenue

Peto v. Commissioner of Internal Revenue
U.S. Court of Appeals for the Second Circuit · Decided December 31, 1958
262 F.2d 342 (Federal Reporter, Second Series)

Peto v. Commissioner of Internal Revenue

Opinion of the Court

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.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.