Clark v. Commissioner
United States Tax Court
Held: (1) Petitioner Robert failed to establish that he employed a cash basis of accounting in the operation of his sole proprietorship engaged in the distribution of filtration equipment and consequently is not entitled to deductions for payments made on business obligations incurred prior to the taxable years.
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Held: (1) Petitioner Robert failed to establish that he employed a cash basis of accounting in the operation of his sole proprietorship engaged in the distribution of filtration equipment and consequently is not entitled to deductions for payments made on business obligations incurred prior to the taxable years. (2) For want of substantiation, petitioners are not entitled to deductions for automobile expenses incurred in connection with the servicing of rental properties in excess of $300 for each of the taxable years allowed by respondent. 260 (3) Petitioners have not established that the…
1Opinion of the Court
Robert E. Clark and Mary B. Clark v. Commissioner.
Clark v. Commissioner
Docket No. 2192-69.
United States Tax Court
T.C. Memo 1971-61; 1971 Tax Ct. Memo LEXIS 270; 30 T.C.M. (CCH) 259; T.C.M. (RIA) 71061;
March 30, 1971. Filed
Held: (1) Petitioner Robert failed to establish that he employed a cash basis of accounting in the operation of his sole proprietorship engaged in the distribution of filtration equipment and consequently is not entitled to deductions for payments made on business obligations incurred prior to the taxable years.(2) For want of substantiation, petitioners are not entitled to…
2Cases cited17 opinions
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
- Commissioner v. Scottish American Investment Co.Supreme Court of the United States · 1945
- Samuel Pollack and Annie Pollack v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Pollack v. CommissionerUnited States Tax Court · 1966
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