Legal Opinion

Robinson v. Commissioner

United States Tax Court

Decided December 31, 1968No. Docket No. 4172-66Published

Petitioner was a theatrical agent who during 1961, 1962, and 1963 visited bars and nightclubs in an effort to obtain contracts to represent entertainers and to sell talent to the clubs. He entertained the performers and buyers of talent. He traveled outside his home area in pursuit of his business. Petitioner used his house to some extent for entertaining and gave certain business gifts.

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Petitioner was a theatrical agent who during 1961, 1962, and 1963 visited bars and nightclubs in an effort to obtain contracts to represent entertainers and to sell talent to the clubs. He entertained the performers and buyers of talent. He traveled outside his home area in pursuit of his business. Petitioner used his house to some extent for entertaining and gave certain business gifts. Petitioner kept a regular set of books listing his income and expenses but did not keep supporting detailed records of his travel, entertainment, and gift expenses. Petitioner in 1961 paid over half the cost…

1Opinion of the Court

John Robinson, Petitioner v. Commissioner of Internal Revenue, Respondent

Robinson v. Commissioner

Docket No. 4172-66

United States Tax Court

51 T.C. 520; 1968 U.S. Tax Ct. LEXIS 1;

December 31, 1968, Filed

Decision will be entered under Rule 50.

Petitioner was a theatrical agent who during 1961, 1962, and 1963 visited bars and nightclubs in an effort to obtain contracts to represent entertainers and to sell talent to the clubs. He entertained the performers and buyers of talent. He traveled outside his home area in pursuit of his business. Petitioner used his house to some extent for entertaining…

Also in this document: Concurrence.

2Cases cited12 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Sanford v. CommissionerUnited States Tax Court · 1968
  3. Commissioner v. BilderSupreme Court of the United States · 1962
  4. Reaver v. CommissionerUnited States Tax Court · 1964
  5. Robinson v. CommissionerUnited States Tax Court · 1968

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