Updated: January 02, 2025 at 05:43 AM
The deduction has been denied on the ground that the premium payments are a capital investment rather than expenses incurred “for the production or collection of income, or for the management, conservation and maintenance of property held for the production of income.”
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1.
U.S. v. Mellinger, 228 F.2d 688 (5th Cir. 1956);
Home News Publishing Co. v. Commissioner, TC Memo 1969-167;
see also Blumenthal v. Commissioner, TC Memo 1963-269,
aff’d, 14 AFTR 2d 5094 (4th Cir. 1964).