15 B.T.A. 1075 | B.T.A. | 1929
Lead Opinion
OPINION.
The petitioner’s first contention is that he should be allowed to take a deduction from gross income in the year 1922 in the
The deduction taken by the petitioner- from his gross income in 1923 can not be allowed. That expense had no possible connection with the petitioner’s income in such year. The purpose of the trip to Europe was not to serve or educate himself but to secure information for the Bar Association. The expenditure, though incurred at the request of the Association, was voluntary. It has not been shown that it was necessary and certainly it was not ordinary. On this point the evidence is not sufficient to overcome the presumption that the Commissioner’s determination is correct. Cf. Albert M. Briggs, 7 B. T. A. 409.
Reviewed by the Board.
Decision mil be entered under.Bule SO.