La Forge v. Commissioner
United States Tax Court
Petitioner, a practicing physician and surgeon, deducted in full in 1964 and 1965 the dues and fees he paid to two country clubs at which he entertained his professional associates and their wives. He also deducted in these same years certain out-of-pocket expenses incurred in buying lunches for residents and interns at the hospitals where he performed surgery.
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Petitioner, a practicing physician and surgeon, deducted in full in 1964 and 1965 the dues and fees he paid to two country clubs at which he entertained his professional associates and their wives. He also deducted in these same years certain out-of-pocket expenses incurred in buying lunches for residents and interns at the hospitals where he performed surgery. Petitioner kept no record whatsoever of these out-of-pocket expenses, but estimated the amount so expended for the years in question. Held, a part of the dues and fees paid to one of the country clubs is deductible under sec. 274(a)…
1Opinion of the Court
IrwtN, Judge:
Respondent determined deficiencies in petitioners’ income taxes for the calendar years 1964 and 1965, in the amounts of $931.28 and $1,044.52, respectively. Petitioner conceded certain issues at trial.
The remaining issues for decision are (1) whether respondent properly disallowed certain club dues and fees claimed by petitioner as entertainment expenses under section 274(a) (1) (B) of the Internal Revenue Code of 1954,1 and (2) whether out-of-pocket expenses incurred at various Buffalo hospitals where petitioner practiced are deductible under sections 162 and 274 as…
2Cases cited5 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Sanford v. CommissionerUnited States Tax Court · 1968
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Sutter v. CommissionerUnited States Tax Court · 1953
3Cited by43 opinions
- Henry Schwartz Corp. v. CommissionerUnited States Tax Court · 1973
- Coors v. CommissionerUnited States Tax Court · 1973
- Nicholls, North, Buse Co. v. CommissionerUnited States Tax Court · 1971
- Kennelly v. CommissionerUnited States Tax Court · 1971
- Mathews v. CommissionerUnited States Tax Court · 1973
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