Legal Opinion

Evans v. Commissioner

United States Tax Court

Decided October 15, 1974No. Docket No. 1807-72UnpublishedCited by 1 opinion

(1) In 1967 and 1968, petitioner incurred and paid certain expenses in the investigation, organization and operation of Venetian International, Inc. and as an employee of that corporation.

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(1) In 1967 and 1968, petitioner incurred and paid certain expenses in the investigation, organization and operation of Venetian International, Inc. and as an employee of that corporation. Held, that petitioner is entitled to deductions under sec. 162 for certain employee business expenses and is entitled to capitalize part of the aforesaid expenditures as an increase to his cost basis in Venetian International, Inc. Held further, since the respondent stipulated the amounts claimed on petitioner's return, except for certain claimed automobile expenses for 1968 of which the mileage was…

1Opinion of the Court

SAM C. and PATRICIA L. EVANS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Evans v. Commissioner

Docket No. 1807-72

United States Tax Court

T.C. Memo 1974-267; 1974 Tax Ct. Memo LEXIS 52; 33 T.C.M. (CCH) 1192; T.C.M. (RIA) 740267;

October 15, 1974, Filed.(1) In 1967 and 1968, petitioner incurred and paid certain expenses in the investigation, organization and operation of Venetian International, Inc. and as an employee of that corporation. Held, that petitioner is entitled to deductions under sec. 162 for certain employee business expenses and is entitled to capitalize part of the…

2Cases cited36 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  4. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  5. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943

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3Cited by1 opinion

  1. Sam C. And Patricia L. Evans v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1977

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