Haft v. Commissioner
United States Tax Court
For many years prior to 1958 petitioner had been engaged in selling costume jewelry to department stores and specialty shops in the southern part of the United States, primarily on a commission basis. His connection with his source of merchandise terminated in 1957; he thereafter actively sought some other connection in the same field.
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For many years prior to 1958 petitioner had been engaged in selling costume jewelry to department stores and specialty shops in the southern part of the United States, primarily on a commission basis. His connection with his source of merchandise terminated in 1957; he thereafter actively sought some other connection in the same field. While thus seeking another connection, petitioner during 1958 continued to make various expenditures for gifts and entertainment of buyers for the establishments with which he had done business over the years. 1. Held, that such expenditures, made during a…
1Opinion of the Court
OPINION
Rattm, Judge:
The Commissioner’s disallowance of deductions for expenses aggregating $11,670.61 in 1958 raises two principal issues: Whether petitioner was engaged in business in 1958, and, if so, whether the challenged expenditures were proximate! y related thereto. The fact that the expenditures were made is not in dispute.
1. Petitioner has spent virtually his entire adult life in the costume jewelry business, and during the period 1932-56 he served as a salesman for Coro, Inc. He worked primarily on a commission basis, earning as much as $60,000 a year, and paying his own expenses.…
2Cases cited7 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Frank v. CommissionerUnited States Tax Court · 1953
- Walet v. CommissionerUnited States Tax Court · 1958
- Koons v. CommissionerUnited States Tax Court · 1961
- Owen v. CommissionerUnited States Tax Court · 1954
2 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Reisinger v. CommissionerUnited States Tax Court · 1979
- Sherman v. CommissionerUnited States Tax Court · 1977
- Gallo v. CommissionerUnited States Tax Court · 1998
- Schnelten v. CommissionerUnited States Tax Court · 1993
- Baist v. CommissionerUnited States Tax Court · 1988
19 more not listed; retrieve them via the Exa API.