Cherry v. Commissioner
United States Tax Court
Held, petitioner's experimental activities at home did not constitute a trade or business during the years involved and expenses incurred in connection therewith are not deductible under secs. 162(a), 212(1), or 165(a) and (c)(1) and (2), I.R.C. 1954. Amount of casualty loss deductible under sec. 165(c)(3), resulting from a fire in 1962, determined.
1Opinion of the Court
Myron Edwin Cherry v. Commissioner.
Cherry v. Commissioner
Docket No. 2180-65.
United States Tax Court
T.C. Memo 1967-123; 1967 Tax Ct. Memo LEXIS 137; 26 T.C.M. (CCH) 557; T.C.M. (RIA) 67123;
June 2, 1967
Held, petitioner's experimental activities at home did not constitute a trade or business during the years involved and expenses incurred in connection therewith are not deductible under secs. 162(a), 212(1), or 165(a) and (c)(1) and (2), I.R.C. 1954.
Amount of casualty loss deductible under sec. 165(c)(3), resulting from a fire in 1962, determined.
James R. Jenks, for the petitioner. John E.…
2Cases cited15 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- McDonald v. CommissionerSupreme Court of the United States · 1944
- International Trading Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1960
- Walet v. CommissionerUnited States Tax Court · 1958
10 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Jack P, Stanton and Virginia G. Stanton v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Edwin A. Snow and Helen B. Snow v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1973
- Snow v. CommissionerUnited States Tax Court · 1972
- Snow v. CommissionerUnited States Tax Court · 1972