Brinson v. Commissioner
United States Tax Court
(1) P, an 80-percent shareholder and officer in X, sold his shares with the assistance of H. Held, P may not deduct under either sec. 162 or 212, I.R.C. 1954, amounts paid to H incident to the sale. (2) P donated his interest in certain equipment to a medical school. Held, P may not deduct under sec. 170, I.R.C. 1954, any amount in excess of his cost as he failed to prove that the fair market value of such equipment exceeded his cost.
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(1) P, an 80-percent shareholder and officer in X, sold his shares with the assistance of H. Held, P may not deduct under either sec. 162 or 212, I.R.C. 1954, amounts paid to H incident to the sale. (2) P donated his interest in certain equipment to a medical school. Held, P may not deduct under sec. 170, I.R.C. 1954, any amount in excess of his cost as he failed to prove that the fair market value of such equipment exceeded his cost. (3) P claimed various expenses for travel, entertainment, gifts, and meals. Held, P may not deduct such expenses as he failed to meet the substantiation…
1Opinion of the Court
JACK C. BRINSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Brinson v. Commissioner
Docket No. 4871-77.
United States Tax Court
T.C. Memo 1981-671; 1981 Tax Ct. Memo LEXIS 70; 42 T.C.M. (CCH) 1712; T.C.M. (RIA) 81671;
November 23, 1981.(1) P, an 80-percent shareholder and officer in X, sold his shares with the assistance of H. Held, P may not deduct under either sec. 162 or 212, I.R.C. 1954, amounts paid to H incident to the sale.(2) P donated his interest in certain equipment to a medical school. Held, P may not deduct under sec. 170, I.R.C. 1954, any amount in excess of his cost…
2Cases cited23 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Sanford v. CommissionerUnited States Tax Court · 1968
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Whipple v. CommissionerSupreme Court of the United States · 1963
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