Walliser v. Commissioner
United States Tax Court
Petitioner, a bank officer responsible for marketing loans, participated in vacation tours attended primarily by builders because social relationships with builders established on the tours generated loan business which helped petitioner meet his assigned loan production quotas and obtain increases in his salary. Held, expenditures for petitioner's vacation tours were ordinary and necessary business expenses.
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Petitioner, a bank officer responsible for marketing loans, participated in vacation tours attended primarily by builders because social relationships with builders established on the tours generated loan business which helped petitioner meet his assigned loan production quotas and obtain increases in his salary. Held, expenditures for petitioner's vacation tours were ordinary and necessary business expenses. Sec. 162(a)(2), I.R.C. 1954. Held, further, vacation tours constituted an "entertainment, amusement, or recreation" activity for purposes of sec. 274(a), I.R.C. 1954, and were subject to…
1Opinion of the Court
Tannenwald, Judge:
Respondent determined a deficiency of $323 in petitioners’ income tax for the taxable year 1973 and a deficiency of $252.45 in petitioners’ income tax for the taxable year 1974. At issue is whether amounts expended by petitioners for foreign travel are deductible as ordinary and necessary business expenses under section 1621 and, if so, whether the requirements of section 274 have been satisfied.2
FINDINGS OF FACT
Some of the facts were stipulated and are found accordingly. The stipulation of facts, together with the exhibits attached thereto, is incorporated herein by this…
2Cases cited11 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Stolk v. CommissionerUnited States Tax Court · 1963
- Henry v. CommissionerUnited States Tax Court · 1961
- Marvin A. Heidt and Beatrice Heidt v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1959
- Larrabee v. CommissionerUnited States Tax Court · 1960
6 more not listed; retrieve them via the Exa API.
3Cited by91 opinions
- Heineman v. CommissionerUnited States Tax Court · 1984
- Anchor Nat'l Life Ins. Co. v. CommissionerUnited States Tax Court · 1989
- Herman v. CommissionerUnited States Tax Court · 1985
- Inv. Research Assocs. v. Comm'rUnited States Tax Court · 2006
- Ireland v. CommissionerUnited States Tax Court · 1987
86 more not listed; retrieve them via the Exa API.