This court cannot subscribe to a general theory that (a) all expenses incurred to maintain physical facilities and management structure during a period when production and shipments of steel products is stopped completely due to a strike may be distinguished in objective and purpose under § 433(b)(9) from (b) all such expenses incurred during other periods. Plaintiff relies on holdings in several Tax Court cases, particularly Arrow-Hart Hegeman Electric Co., 7 T.C. 1350 (1946) and National Biscuit Co., 29 T.C. 409 (1957). However, none of the holdings in cases cited by plaintiff applies to the record presented in the instant case.
At the outset we believe that the deduction for officers' compensation constitutes a ‘class of deductions' within the meaning of section 433(b)(9). McKay Machine Co., 28 T.C. 185; National Biscuit Co., 29 T.C. 409; Universal Optical Co., 11 T.C. 608; and Mine & Smelter Supply Co., 10 T.C. 1179. Respondent makes the argument that the ‘class of deductions' contemplated by the section must be intrinsically abnormal for the taxpayer in the regular operation of a business, that is, a class which is nonrecurrent for the particular taxpayer.