Bane v. Commissioner
United States Tax Court
Petitioner, an attorney, claimed substantial deductions for entertainment and business gifts. Held: (1) He cannot subpoena the tax returns of other attorneys because he has not shown that such returns would be relevant; and (2) He has failed to substantiate his alleged expenditures for entertainment and business gifts in the manner required by sec. 274(d), I.R.C. 1954, and failed to prove that his expenditures for entertainment were directly related to or associated with his…
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Petitioner, an attorney, claimed substantial deductions for entertainment and business gifts. Held: (1) He cannot subpoena the tax returns of other attorneys because he has not shown that such returns would be relevant; and (2) He has failed to substantiate his alleged expenditures for entertainment and business gifts in the manner required by sec. 274(d), I.R.C. 1954, and failed to prove that his expenditures for entertainment were directly related to or associated with his business within the meaning of sec. 274(a), I.R.C. 1954.
1Opinion of the Court
Charles A. and Eileen B. Bane v. Commissioner.
Bane v. Commissioner
Docket No. 1616-67.
United States Tax Court
T.C. Memo 1971-31; 1971 Tax Ct. Memo LEXIS 302; 30 T.C.M. (CCH) 125; T.C.M. (RIA) 71031;
February 11, 1971, Filed
Petitioner, an attorney, claimed substantial deductions for entertainment and business gifts.
Held: (1) He cannot subpoena the tax returns of other attorneys because he has not shown that such returns would be relevant; and(2) He has failed to substantiate his alleged expenditures for entertainment and business gifts in the manner required by sec. 274(d), I.R.C. 1954, and…
2Cases cited37 opinions
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- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
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