Sutherland Lumber-Southwest, Inc. v. Commissioner
United States Tax Court
P provided its employees with the use of the company-owned aircraft for nonbusiness flights. P notified its employees to report the value of the flights as imputed income. P deducted the expenses incurred in providing the flights. R, relying on sec. 274(e)(2), I.R.C., determined that deductions for expenses incurred in providing employees with nonbusiness flights on a company-owned airplane are limited to the amount reported as imputed income to the recipient employees.
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P provided its employees with the use of the company-owned aircraft for nonbusiness flights. P notified its employees to report the value of the flights as imputed income. P deducted the expenses incurred in providing the flights. R, relying on sec. 274(e)(2), I.R.C., determined that deductions for expenses incurred in providing employees with nonbusiness flights on a company-owned airplane are limited to the amount reported as imputed income to the recipient employees. P contends that its expense deductions are not subject to sec. 274, I.R.C., or, in the alternative, if subject to sec. 274,…
1Opinion of the Court
OPINION
Gerber, Judge:
The parties filed cross-motions for partial summary judgment, seeking resolution of whether petitioner is allowed to deduct its expenses in operating its company aircraft for the benefit of employees or whether the deduction is limited to the value of the use of the aircraft — the amount reportable by petitioner’s employees. The parties’ controversy raises the question of whether and how section 2741 applies for petitioner’s 1992 and 1993 taxable years.
Background
Petitioner is a corporation with its principal place of business in Kansas City, Missouri. Petitioner’s…
2Cases cited14 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Naftel v. CommissionerUnited States Tax Court · 1985
9 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Griffin v. Comm'rUnited States Tax Court · 2004
- Robinson v. United StatesUnited States Court of Federal Claims · 2002
- Sutherland Lumber-Southwest, Inc. v. CommissionerCourt of Appeals for the Eighth Circuit · 2001
- Sutherland Lumber-Southwest, Inc. v. CommissionerUnited States Tax Court · 2000
- Sutherland Lumber-Southwest, Inc. v. CommissionerUnited States Tax Court · 2000
1 more not listed; retrieve them via the Exa API.