Legal Opinion

Berkley Machine Works & Foundry Co. v. Commissioner

United States Tax Court

Decided August 15, 1983No. Docket No. 485-76, 3683-77, 22859-80Unpublished

1. Petitioner owned and maintained three buildings on Ocracoke Island, North Carolina, which it used, as hunting and fishing lodges, for the entertainment of employees of its major customers and a few of its smaller customers during 1968 through 1978. Petitioner's officers would decide which customer-companies were to be invited on a particular hunting and/or fishing trip to Ocracoke, and the sales representatives for the customers would phone contacts of theirs in a…

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1. Petitioner owned and maintained three buildings on Ocracoke Island, North Carolina, which it used, as hunting and fishing lodges, for the entertainment of employees of its major customers and a few of its smaller customers during 1968 through 1978. Petitioner's officers would decide which customer-companies were to be invited on a particular hunting and/or fishing trip to Ocracoke, and the sales representatives for the customers would phone contacts of theirs in a position of authority in the companies, who would in turn designate the employees who were to go. Held, deductions for…

1Opinion of the Court

BERKLEY MACHINE WORKS & FOUNDRY COMPANY, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Berkley Machine Works & Foundry Co. v. Commissioner

Docket No. 485-76, 3683-77, 22859-80

United States Tax Court

T.C. Memo 1983-477; 1983 Tax Ct. Memo LEXIS 306; 46 T.C.M. (CCH) 1060; T.C.M. (RIA) 83477;

August 15, 1983.

1. Petitioner owned and maintained three buildings on Ocracoke Island, North Carolina, which it used, as hunting and fishing lodges, for the entertainment of employees of its major customers and a few of its smaller customers during 1968 through 1978. Petitioner's officers…

2Cases cited34 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Commissioner v. SunnenSupreme Court of the United States · 1948
  3. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  4. Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
  5. United States v. Consolidated Edison Co. of NYSupreme Court of the United States · 1961

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