Industrial Research Products, Inc. v. Commissioner
United States Tax Court
1. Held, taxpayers are entitled to full bond premium amortization deductions on 1954 bond purchases based on the call price of the bonds and such deductions are not limited to the "put" or "buyback" options granted by the bond seller. 2. Held, further, under the facts, a corporate executive and employee was not engaged in carrying on a business as consulting engineer or inventor in his own home and therefore the expenses he took as business expenses were properly disallowed.
1Opinion of the Court
Mulroney, Judge:
The respondent determined deficiencies In these consolidated cases, as follows:
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The questions to be decided are the correctness of the deductions taken by petitioners in both dockets for bond premium amortization under section 125 of the 1939 Code and section 171 of the 1954 Code and whether petitioners in docket No. 81976 are entitled to a claimed business expense deduction.
FINDINGS OF FACT
Some of the facts were stipulated and they are found accordingly.
Industrial Research Products, Inc., hereinafter referred to as Industrial, was incorporated under the laws of…
2Cases cited4 opinions
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Commissioner v. KorellSupreme Court of the United States · 1950
- Anna J. McDowell v. Abraham A. Ribicoff, Secretary of Health, Welfare and EducationCourt of Appeals for the Third Circuit · 1961
3Cited by21 opinions
- Jack P, Stanton and Virginia G. Stanton v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Snow v. CommissionerUnited States Tax Court · 1972
- Stanton v. CommissionerUnited States Tax Court · 1967
- Milton L. Halle and Rachel N. Halle, His Wife v. United StatesCourt of Appeals for the Fourth Circuit · 1965
- Starr v. CommissionerUnited States Tax Court · 1966
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