Legal Opinion

Tank Truck Rentals v. Commissioner

United States Tax Court

Decided May 31, 1956No. Docket No. 51051Published

1. Fines paid by petitioner, engaged in the business of transporting bulk liquids by motor vehicles, for violation of State laws prescribing maximum weight limitations, are not deductible from its gross income as ordinary and necessary business expenses. 2. Where petitioner was obligated by contract to pay fines imposed upon drivers of its vehicles by the State of Pennsylvania for violation of weight limitation laws, and, during the taxable year, paid fines for such…

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1. Fines paid by petitioner, engaged in the business of transporting bulk liquids by motor vehicles, for violation of State laws prescribing maximum weight limitations, are not deductible from its gross income as ordinary and necessary business expenses. 2. Where petitioner was obligated by contract to pay fines imposed upon drivers of its vehicles by the State of Pennsylvania for violation of weight limitation laws, and, during the taxable year, paid fines for such violations, the amounts paid are not deductible under the provisions of section 23 (a) (1) (A) of the Internal Revenue Code of…

1Opinion of the Court

Tank Truck Rentals, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Tank Truck Rentals v. Commissioner

Docket No. 51051

United States Tax Court

26 T.C. 427; 1956 U.S. Tax Ct. LEXIS 181;

May 31, 1956, Filed

Decision will be entered for the respondent.

1. Fines paid by petitioner, engaged in the business of transporting bulk liquids by motor vehicles, for violation of State laws prescribing maximum weight limitations, are not deductible from its gross income as ordinary and necessary business expenses.

2. Where petitioner was obligated by contract to pay fines imposed upon drivers of…

2Cases cited15 opinions

  1. Commissioner v. HeiningerSupreme Court of the United States · 1943
  2. Lilly v. CommissionerSupreme Court of the United States · 1952
  3. Jerry Rossman Corporation v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1949
  4. Commonwealth v. BurallSuperior Court of Pennsylvania · 1941
  5. Great Northern Ry. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1930

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