Stonebrook v. Commissioner
United States Tax Court
Ps. who were farmers, contracted with an individual, who was related to them, to harvest their crop. In harvesting the crop, the individual furnished little or none of the required equipment and materials and essentially provided only her personal services. Ps paid her a substantial fee.
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Ps. who were farmers, contracted with an individual, who was related to them, to harvest their crop. In harvesting the crop, the individual furnished little or none of the required equipment and materials and essentially provided only her personal services. Ps paid her a substantial fee. Held, the Commissioner's disallowance of a deduction for a portion of the fee sustained, since Ps failed to prove that any amount greater than that allowed by the Commissioner was an ordinary and necessary business expense under sec. 162(a), I.R.C. 1954.
1Opinion of the Court
EDWARD E. STONEBROOK, GERTRUDE STONEBROOK, MELVIN D. EDIGER, and ESTHER R. EDIGER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Stonebrook v. Commissioner
Docket No. 11599-78.
United States Tax Court
T.C. Memo 1980-522; 1980 Tax Ct. Memo LEXIS 60; 41 T.C.M. (CCH) 422; T.C.M. (RIA) 80522;
November 25, 1980, Filed
Ps. who were farmers, contracted with an individual, who was related to them, to harvest their crop. In harvesting the crop, the individual furnished little or none of the required equipment and materials and essentially provided only her personal services. Ps paid her a…
2Cases cited10 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner v. TowerSupreme Court of the United States · 1946
- Sanford v. CommissionerUnited States Tax Court · 1968
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
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