Marquis v. Commissioner
United States Tax Court
Petitioner, a travel agent, regularly transacted a large portion of her business with clients which were exempt as charitable organizations under sec. 170. At the end of each year, she made payments to them keyed to the amount, character, and profitability of such business. Held, under all the circumstances, such payments were not charitable contributions and, therefore, the limitation of sec. 162(b) did not preclude deductibility in full as business expenses.
1Opinion of the Court
Sarah Marquis, Petitioner v. Commissioner of Internal Revenue, Respondent
Marquis v. Commissioner
Docket No. 3298-66
United States Tax Court
49 T.C. 695; 1968 U.S. Tax Ct. LEXIS 155;
March 29, 1968, Filed
Decision will be entered under Rule 50.
Petitioner, a travel agent, regularly transacted a large portion of her business with clients which were exempt as charitable organizations under sec. 170. At the end of each year, she made payments to them keyed to the amount, character, and profitability of such business. Held, under all the circumstances, such payments were not charitable contributions…
2Cases cited14 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Harold Dejong and Marjorie J. Dejong v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- United States v. Transamerica Corporation, Transamerica Corporation v. United StatesCourt of Appeals for the Ninth Circuit · 1968
- Perlmutter v. CommissionerUnited States Tax Court · 1965
- Channing v. United StatesDistrict Court, D. Massachusetts · 1933
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