Supreme Court of the United States, 1933

Justice Cardozo delivered the Court's opinion affirming the denial of deductions for payments a commission agent voluntarily made to creditors of his former bankrupt employer to improve his own credit and business standing.

The Court held that a waiver of the statute of limitations under §278(e) of the Revenue Act of 1924 is effective even though it was executed after the five‑year limitation period had already expired, so the assessment of additional tax for 1917 was valid.