Peto v. Commissioner of Internal Revenue
Peto v. Commissioner of Internal Revenue
262 F.2d 342
(Federal Reporter, Second Series)
Peto v. Commissioner of Internal Revenue
Opinion of the Court
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.