Kennelly v. Commissioner
United States Tax Court
Held: 1. The petitioner has failed to meet the substantiation requirements of sec. 274(d) with respect to entertainment expenses claimed to have been incurred in 1965 and 1966 in his capacity as an employee of This Week Magazine. 2. The petitioner has failed to demonstrate that entertainment expenses claimed to have been incurred in connection with his business as a playwright were "ordinary" within the meaning of sec. 162. 3. The taxi expenses claimed by the petitioner in…
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Held: 1. The petitioner has failed to meet the substantiation requirements of sec. 274(d) with respect to entertainment expenses claimed to have been incurred in 1965 and 1966 in his capacity as an employee of This Week Magazine. 2. The petitioner has failed to demonstrate that entertainment expenses claimed to have been incurred in connection with his business as a playwright were "ordinary" within the meaning of sec. 162. 3. The taxi expenses claimed by the petitioner in 1965 and 1966, in excess of the amounts allowed by the respondent were reimbursable by the petitioner's employer, This…
1Opinion of the Court
Quealy, Judge:
The respondent determined deficiencies in the Federal income taxes of the petitioners as follows:
Year Deficiency
1965 _$1,005.34
1966 _ 568.43
As to both of the years in question, the petitioners have conceded the disallowance by the respondent of their claimed deductions for apparel, makeup, and hairdressing expenses purportedly incurred by petitioner Selma Kennelly. Consequently, the only issues remaining for our determination are:(1) Whether the petitioners are entitled to deductions for entertainment expenses for the taxable years 1965 and 1966 in the respective amounts of…
2Cases cited7 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Lilly v. CommissionerSupreme Court of the United States · 1952
- Podems v. CommissionerUnited States Tax Court · 1955
2 more not listed; retrieve them via the Exa API.
3Cited by55 opinions
- Henry Schwartz Corp. v. CommissionerUnited States Tax Court · 1973
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- Mathews v. CommissionerUnited States Tax Court · 1973
- Rutz v. CommissionerUnited States Tax Court · 1976
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