Tank Truck Rentals, Inc. v. Commissioner 356 U.S. 30 (1958) Each State has licensing requirements for trucks, and the cost of the license is related to the amount of weight the truck can carry. Trucks are supposed to stop at highway 'weigh stations' to check if they are over their weight limits. Tank Truck made a business decision to sometimes overload their trucks even though it meant they would occasionally get caught and have to pay a fine. Tank Truck calculated that the costs of the fines were less than the costs of upgrading their licenses. When they filed their taxes, Tank Truck claimed a deduction for the fines as a business expense. The IRS denied the deduction. Tank Truck appealed. Tank Truck claimed that the fines were an ordinary and necessary expense and therefore deductible under 26 U.S.C. § 23(a)(1)(A) (now 26 U.S.C. §162). Tank Truck argued that it was a minor law, and it was similar to a decision to repudiate a civil contract. The IRS argued that it is never ordinary and necessary to violate the law. Therefore, there must be a policy limitation that would deny a deduction for violating the law. The US Supreme Court found for the IRS. The US Supreme Court interpreted the words ordinary and necessary, should not include punishment by a State government for violating a law. The Court found that allowing the deduction would "frustrate national or state policies proscribing particular types of conduct." Since this case, Congress has codified the holding that fines are not deductible in 26 U.S.C. §162(f).