Hearn v. Commissioner
United States Tax Court
1. Entertainment and other expenses claimed by T, a lawyer, in excess of amounts allowed by the Commissioner, largely unsubstantiated and not convincingly shown to have any proximate relationship to T's business, held not deductible from gross income as ordinary and necessary business expenses. 2. Advances on behalf of clients by T held not deductible when made, even though regarded as "doubtful" by T, where he was entitled to reimbursement and in fact did receive…
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1. Entertainment and other expenses claimed by T, a lawyer, in excess of amounts allowed by the Commissioner, largely unsubstantiated and not convincingly shown to have any proximate relationship to T's business, held not deductible from gross income as ordinary and necessary business expenses. 2. Advances on behalf of clients by T held not deductible when made, even though regarded as "doubtful" by T, where he was entitled to reimbursement and in fact did receive reimbursement of the bulk of such advances in subsequent years. Cf. Henry F. Cochrane, 23 B.T.A. 202.
1Opinion of the Court
OPINION.
Raum, Judge:
The Commissioner determined deficiencies in income tax against petitioners, husband and wife, for the years 1951-1956 in the amounts of $1,781.99, $8,133.22, and $11,352.56, respectively. They filed their returns with the district director of internal revenue at San Francisco. A series of adjustments with respect to all 3 years, referred to as “business expenses,” is presently in issue. The husband is an attorney, and the alleged expenses in question were claimed as deductions relating to his practice of law. He will hereinafter be referred to as petitioner.
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2Cases cited4 opinions
- Walet v. CommissionerUnited States Tax Court · 1958
- Eugene H. Walet, Jr. And Celia R. Walet v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- Larrabee v. CommissionerUnited States Tax Court · 1960
- Cochrane v. CommissionerUnited States Board of Tax Appeals · 1931
3Cited by56 opinions
- Michaels v. CommissionerUnited States Tax Court · 1969
- Stolk v. CommissionerUnited States Tax Court · 1963
- Neaderland v. CommissionerUnited States Tax Court · 1969
- Canelo v. CommissionerUnited States Tax Court · 1969
- Charles Baloian Co. v. CommissionerUnited States Tax Court · 1977
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