Legal Opinion

Cremona v. Commissioner

United States Tax Court

Decided May 4, 1972No. Docket No. 7121-70Published

The taxpayer was employed as an "administrator." In 1968, he engaged the services of a job-counseling organization for a flat fee of $ 1,500 to assist him in obtaining a better job. The taxpayer did not succeed in obtaining any offers of employment as a result of such services and remained employed at his old job. Held, the fee paid by the taxpayer is deductible as an ordinary and necessary business expense. Sec. 162(a), I.R.C. 1954.

1Opinion of the Court

Leonard F. Cremona and Marie Cremona, Petitioners v. Commissioner of Internal Revenue, Respondent

Cremona v. Commissioner

Docket No. 7121-70

United States Tax Court

58 T.C. 219; 1972 U.S. Tax Ct. LEXIS 133;

May 4, 1972, Filed

Decision will be entered under Rule 50.

The taxpayer was employed as an "administrator." In 1968, he engaged the services of a job-counseling organization for a flat fee of $ 1,500 to assist him in obtaining a better job. The taxpayer did not succeed in obtaining any offers of employment as a result of such services and remained employed at his old job. Held, the fee paid by…

Also in this document: Concurrence · Drennen; Concurrence · Tannenwald; Concurrence · Sterrett.

2Cases cited6 opinions

  1. United States v. GeneresSupreme Court of the United States · 1972
  2. Primuth v. CommissionerUnited States Tax Court · 1970
  3. Cremona v. CommissionerUnited States Tax Court · 1972
  4. Motto v. CommissionerUnited States Tax Court · 1970
  5. Carter v. CommissionerUnited States Tax Court · 1969

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