Welch

In this case we are concerned with plaintiff’s asserted right to income tax deductions, as hereinafter stated. Coneededly, plaintiff’s books were kept on the accrual basis, one of two systems of keeping books relating to business transactions recognized by the Internal Revenue Department. In plaintiff’s income tax return filed for the year 1919, ’ it claimed a deduction of $38,559.17, arising out of the delivery of a series of promissory notes payable in monthly installments within the year 1920, and one note in January, 1921, given respectively to the La Fountain Bulletin Service and the Foster & Kleiser Company for billboard advertising. The promissory notes were given as future installments for such advertising (during a period of 12 months), and, though regarded as a necessary business expense, based upon the advertising companies agreeing to perform services and acceptance by them in full payment for the *305 particular services for the year 1920, it is nevertheless questionable whether the plaintiff’s deductions from gross income were justified as a liability incurred for the year 1919. None, of the services apparently were to be performed at the end of the year when the…