Epp v. Commissioner
United States Tax Court
P paid $ 2,000 to the Institute of Individual Religious Studies for information, guidance, and written materials to be used to establish a family estate trust. Subsequently, P established and transferred assets to such a trust. Held, P failed to prove that any part of such payment was an ordinary and necessary expenditure paid for the management, conservation, or maintenance of property held for the production of income or for tax advice. Sec. 212(2) and ( 3), I.R.C. 1954.
1Opinion of the Court
Simpson, Judge: *
The Commissioner determined a deficiency of $848 in the petitioner’s Federal income tax for 1976 and an addition to tax of $42.40 under section 6653(a) of the Internal Revenue Code of 1954.1 By agreement of the parties, the sole issue for decision at this time is whether the petitioner is entitled to deduct under section 212 the expenses of establishing á family estate trust.2
FINDINGS OF FACT
Some of the facts have been stipulated, and those facts are so found.
The petitioner, Susan H. Epp, resided at 324 Stanley Street, Medford, Oreg., at the time she filed her petition in…
2Cases cited24 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- W. Horace Williams, Sr., and Viola Bloch Williams v. United StatesCourt of Appeals for the Fifth Circuit · 1957
- Brotherhood of Locomotive Engineers v. Louisville & Nashville RailroadSupreme Court of the United States · 1963
- Frank v. CommissionerUnited States Tax Court · 1953
19 more not listed; retrieve them via the Exa API.
3Cited by49 opinions
- Zmuda v. CommissionerUnited States Tax Court · 1982
- Luman v. CommissionerUnited States Tax Court · 1982
- Professional Services v. CommissionerUnited States Tax Court · 1982
- Ronnen v. CommissionerUnited States Tax Court · 1988
- Johnsen v. CommissionerUnited States Tax Court · 1984
44 more not listed; retrieve them via the Exa API.