Cravens v. Commissioner
United States Tax Court
Held, that petitioner's payment of $ 50,000 on December 29, 1953, to Superior Feed Mills was a deposit against which any future purchases were to be applied. Such amount was not an ordinary and necessary business expense deductible in full in 1953 by petitioner.
1Opinion of the Court
Fisher, Judge:
Respondent determined a deficiency of $38,995.04 in petitioners’ income tax for the year 1953.
The principal issue before the Court is whether the amount of $50,000, which was given to Superior Feed Mills in December 1953, was an ordinary and necessary business expense deductible in full in that year.
Ida Cravens is the wife of E. D. Cravens and is also a petitioner because they filed joint tax returns. She was not active in the business operations of E. D. Cravens.
FINDINGS OP PACT.
Some of the facts have been stipulated and are incorporated herein by this reference.
Petitioners are…
2Cases cited5 opinions
- Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
- Veenstra & De Haan Coal Co. v. CommissionerUnited States Tax Court · 1948
- Bauer Bros. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1931
- Rose v. United StatesCourt of Appeals for the Third Circuit · 1958
- Ogle v. Oklahoma City Horse & Mule Com. Co.Supreme Court of Oklahoma · 1935
3Cited by29 opinions
- Sandor v. CommissionerUnited States Tax Court · 1974
- Van Raden v. CommissionerUnited States Tax Court · 1979
- Packard v. CommissionerUnited States Tax Court · 1985
- R D. And Ida M. Cravens v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1959
- Owens v. CommissionerUnited States Tax Court · 1975
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