Legal Opinion
Dana W. Brown v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided August 3, 1971No. 20638PublishedCited by 6 opinions
1Opinion of the Court
LAY, Circuit Judge.
The fundamental issue before us is whether certain expenses incurred by a corporate executive may be personally deducted as “ordinary and necessary” expenses of his employment under § 162 of the Internal Eevenue Code of 1954. 1 The taxpayer appeals from an adverse finding of the Tax Court. 29 T.C. Memo. 1126 (1970).
During the taxable years of 1962, 1963 and 1964 the taxpayer, Dana Brown, was employed as president of Manhattan Coffee Co. (hereinafter Manhattan). He owned no stock in the company. As president, taxpayer was primarily responsible for the sales of Manhattan…
2Cases cited10 opinions
- Podems v. CommissionerUnited States Tax Court · 1955
- Stolk v. CommissionerUnited States Tax Court · 1963
- Lloyd U. Noland, Jr., and Jane K. Noland v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1959
- Marvin A. Heidt and Beatrice Heidt v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1959
- Edward Folker v. James W. Johnson, Individually and as a Former Collector of Internal RevenueCourt of Appeals for the Second Circuit · 1956
5 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Lavern Scherping v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1984
- Kessler v. CommissionerUnited States Tax Court · 1985
- Eckel v. CommissionerUnited States Tax Court · 1974
- Patterson v. CommissionerUnited States Tax Court · 1971
- Posluns v. Comm'rUnited States Tax Court · 2012
1 more not listed; retrieve them via the Exa API.