Appeal of MASON COTTON MILLS COMPANY

Appeal of MASON COTTON MILLS COMPANY. Docket No. 448. A list of payments claimed to be deductible expenses allowed in part and disallowed in part on tbe evidence. Submitted January 12, 1925; decided January 30, 1925. John G. Kramer, Esq., for the taxpayer. Arthur H. Fast, Esq. (Nelson T. Hartson, Solicitor of Internal Revenue) for the Commissioner. Before James, Sternhagen, Tkammell, and Trussell. The taxpayer originally claimed an amount of $12,733.08 as deductions for ordinary and' necessary business expenses of repairs and maintenance. Of this amount the Commissioner allowed $1,000 and based a deficiency upon the disallowance of the remainder. The deficiency asserted by the Commissioner is less than $10,000. FINDINGS OF FACT. The taxpayer paid in 1918 the following amounts as ordinary and necessary business expenses: Paint for painting bobbins- $131.30 Lumber for repairing steps, ceilings, shingling, floors, and packing cases_ 4, 895. 93 Card clothing repairs, out of a total expenditure, some of which was apparently for complete replacement_ 664. 29 Machine work, overhauling and repairing machinery_ 1,158. 93 Labor_ 566.42 Freight_ 484.30 Total allowable_ 7, 901.17 The remaining items aggregating $4,S31.91 have not been proven and their disallowance is approved. [MAJORITY] DECISION. The deficiency should be recomputed after allowing the above items as deductible expenses. Final determination will be made on seven days’ notice in accordance with Rule 50.