Johnson v. Commissioner
United States Tax Court
During the years 1951 and 1952, petitioner, who is a corporate executive, received certain amounts from his employer as reimbursement for amounts expended on behalf of the employer for travel, entertainment, and sales promotion activities. Petitioner did not include these amounts in the gross income stated on his returns, nor did he claim any expenses on the returns in connection therewith.
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During the years 1951 and 1952, petitioner, who is a corporate executive, received certain amounts from his employer as reimbursement for amounts expended on behalf of the employer for travel, entertainment, and sales promotion activities. Petitioner did not include these amounts in the gross income stated on his returns, nor did he claim any expenses on the returns in connection therewith. Respondent included the total reimbursement in petitioner's income, which total amount was in excess of 25 per cent of the gross income reported on the returns. Respondent also allowed certain expenses as…
1Opinion of the Court
OPINION.
Fisher, Judge:
Respondent determined deficiencies in petitioners’ income tax and additions thereto as follows:
Additions to tax, Tear Deficiency sec. 294(d) (S)1
1951_$1, 530. 06 $176.27
1952_ 2,342.86 146.73
The issue presented is whether the amounts of $7,722.73 and $10,-790.26 received by Abbott Johnson during the years 1951 and 1952, respectively, from his employer as reimbursement for amounts expended by Johnson for travel, entertainment, and sales promotion activities on behalf of his employer are properly includible in gross income to the extent that they result in a washout, for…
2Cases cited3 opinions
- Switzer v. CommissionerUnited States Tax Court · 1953
- United States v. BenedictSupreme Court of the United States · 1950
- Maloy v. CommissionerUnited States Board of Tax Appeals · 1941
3Cited by6 opinions
- Grapevine Imports, Ltd. v. United StatesUnited States Court of Federal Claims · 2007
- Cardinal Life Insurance v. United StatesDistrict Court, N.D. Texas · 1969
- Scallen v. CommissionerUnited States Tax Court · 1987
- Estate of Lennen v. CommissionerUnited States Tax Court · 1962
- Johnson v. CommissionerUnited States Tax Court · 1959
1 more not listed; retrieve them via the Exa API.