Elliott v. Commissioner
United States Tax Court
Ps conducted an Amway distributorship in the evenings and on weekends during the years in issue. They claimed deductions for various business expenses which were allegedly necessary to the Amway distributorship. Ps submitted records to support their claimed deductions consisting of a notebook with incomplete entries and many unannotated receipts. Ps conducted the Amway distributorship in an unbusinesslike fashion.
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Ps conducted an Amway distributorship in the evenings and on weekends during the years in issue. They claimed deductions for various business expenses which were allegedly necessary to the Amway distributorship. Ps submitted records to support their claimed deductions consisting of a notebook with incomplete entries and many unannotated receipts. Ps conducted the Amway distributorship in an unbusinesslike fashion. Held, Ps failed to show that they engaged in the Amway distributorship with the actual and honest objective of making a profit, and, therefore, Ps improperly claimed deductions for…
1Opinion of the Court
Thomas O. and Carol J. Elliott, Petitioners v. Commissioner of Internal Revenue, Respondent
Elliott v. Commissioner
Docket No. 10175-85
United States Tax Court
90 T.C. 960; 1988 U.S. Tax Ct. LEXIS 64; 90 T.C. No. 63;
May 11, 1988. May 11, 1988, Filed
Decision will be entered for the respondent.
Ps conducted an Amway distributorship in the evenings and on weekends during the years in issue. They claimed deductions for various business expenses which were allegedly necessary to the Amway distributorship. Ps submitted records to support their claimed deductions consisting of a notebook with incomplete…
2Cases cited20 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Neely v. CommissionerUnited States Tax Court · 1985
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Golanty v. CommissionerUnited States Tax Court · 1979
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