Commissioner of Internal Revenue v. Guminski

STRUM, Circuit Judge

(dissenting).

With deference to the able judges, in this circuit and elsewhere, who have taken the opposite view, I am opposed to an interpretation of the tax laws which will enable a taxpayer to gain a tax advantage •by violating the price stabilization laws, thus placing himself in a better position than had he obeyed the law.

The taxing authorities should not be compelled to recognize a merchandise “cost,” the payment of which is expressly proscribed and denounced as a crime by federal law. “Cost,” as used in Treasury Regulation 111, Sec. 29.22(a)-5, means “lawful cost.”

I therefore dissent.