Henry v. Commissioner
United States Tax Court
Petitioner, a tax lawyer and accountant, purchased a yacht on which he flew a red, white, and blue pennant with the numerals "1040" on it, purportedly to provoke inquiries and thus promote petitioner's business by giving him contacts with people in yachting circles who might become clients in the future.
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Petitioner, a tax lawyer and accountant, purchased a yacht on which he flew a red, white, and blue pennant with the numerals "1040" on it, purportedly to provoke inquiries and thus promote petitioner's business by giving him contacts with people in yachting circles who might become clients in the future. Held, the cost of insurance and maintenance of the yacht, and depreciation thereon, are not deductible as ordinary and necessary expenses paid or incurred in carrying on petitioner's trade or business for the year 1954.
1Opinion of the Court
Drennen, Judge:
In this proceeding respondent determined a deficiency in income tax due from petitioners for the taxable year 1954 in the amount of $4,375.88.
The only issue for decision is whether petitioners are entitled to business deductions for the taxable year 1954, representing the expenses of maintenance and depreciation of a yacht during that year.
FINDINGS OF FACT.
Petitioners were husband and wife, residing in New York, New York, during the year 1954. They filed a joint Federal income tax return for the taxable year 1954 with the district director of internal revenue, Upper Manhattan…
2Cases cited10 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- McDonald v. CommissionerSupreme Court of the United States · 1944
- Sutter v. CommissionerUnited States Tax Court · 1953
- Boehm v. CommissionerUnited States Board of Tax Appeals · 1937
5 more not listed; retrieve them via the Exa API.
3Cited by84 opinions
- Carroll v. CommissionerUnited States Tax Court · 1968
- Walliser v. CommissionerUnited States Tax Court · 1979
- Andress v. CommissionerUnited States Tax Court · 1969
- Heineman v. CommissionerUnited States Tax Court · 1984
- Bradley v. CommissionerUnited States Tax Court · 1970
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