United States Board of Tax Appeals June 29, 1925, Docket No. 2477 (Appeal of American Textiles, Inc.)

*188OPINION.

Green:

The execution and. performance of the agreement by the Smiths and Galbraiths was not a service the cost of which is a deductible expense. The expense was not an ordinary and necessary business expense, nor can it be called compensation for personal services. The exchange of stock was, if anything, a capital transaction.