Andress v. Commissioner
United States Tax Court
Petitioner, a practicing attorney, claimed deductions for "courtesy and promotion" expenditures in 1964 and 1965, consisting of purchases of liquor used at social gatherings at his residence, the payment of dues, food, and drinks at two private clubs, and certain undesignated items.
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Petitioner, a practicing attorney, claimed deductions for "courtesy and promotion" expenditures in 1964 and 1965, consisting of purchases of liquor used at social gatherings at his residence, the payment of dues, food, and drinks at two private clubs, and certain undesignated items. Held, that the expenditures constitute "entertainment" expenses under sec. 274, I.R.C. 1954; that petitioner has failed to establish that the expenditures were directly related to the active conduct of his business as required by sec. 274(a)(1) and the regulations promulgated thereunder; and that petitioner has…
1Opinion of the Court
Wm. Andress, Jr., and DeVona C. Andress, Petitioners v. Commissioner of Internal Revenue, Respondent
Andress v. Commissioner
Docket No. 609-67
United States Tax Court
51 T.C. 863; 1969 U.S. Tax Ct. LEXIS 181;
February 27, 1969, Filed
Decision will be entered under Rule 50.
Petitioner, a practicing attorney, claimed deductions for "courtesy and promotion" expenditures in 1964 and 1965, consisting of purchases of liquor used at social gatherings at his residence, the payment of dues, food, and drinks at two private clubs, and certain undesignated items. Held, that the expenditures constitute…
2Cases cited8 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Sanford v. CommissionerUnited States Tax Court · 1968
- Ashby v. CommissionerUnited States Tax Court · 1968
- Henry v. CommissionerUnited States Tax Court · 1961
- Boehm v. CommissionerUnited States Board of Tax Appeals · 1937
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