Wallendal v. Commissioner
United States Tax Court
1. Held, that interest paid by the principal petitioner on the unpaid balance of the price for acquiring a share in a laundry partnership business, did not constitute an expense attributable to a trade or business carried on by him, within the meaning of section 22(n)(1), I.R.C. 1939; and, accordingly, that the amount of such interest is not deductible in computing said petitioner's adjusted gross income. 2. Held, further, that neither the amounts claimed to have been…
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1. Held, that interest paid by the principal petitioner on the unpaid balance of the price for acquiring a share in a laundry partnership business, did not constitute an expense attributable to a trade or business carried on by him, within the meaning of section 22(n)(1), I.R.C. 1939; and, accordingly, that the amount of such interest is not deductible in computing said petitioner's adjusted gross income. 2. Held, further, that neither the amounts claimed to have been expended by the principal petitioner in buying drinks and food for patrons of taverns and restaurants, whom he regarded to be…
1Opinion of the Court
Pierce, Judge:
Respondent determined a deficiency of $206.32 in petitioners’ income tax for the calendar year 1953.
The issues presented are:(1) Whether the amount of $499.06 paid by the principal petitioner as interest on the unpaid balance of the contract price for his purchase of a share in a business partnership, is an expense attributable to a “trade or business carried on by the taxpayer” within the meaning of section 22 (n) (1) of the Internal Revenue Code of 1939, so as to be deductible from his gross income in computing adjusted gross income.(2) Whether the following other amounts are…
2Cases cited4 opinions
- Frank v. CommissionerUnited States Tax Court · 1953
- Polachek v. CommissionerUnited States Tax Court · 1954
- Owen v. CommissionerUnited States Tax Court · 1954
- Wilson v. CommissionerUnited States Board of Tax Appeals · 1929
3Cited by30 opinions
- Fred W. Amend Co. v. CommissionerUnited States Tax Court · 1970
- Cropland Chem. Corp. v. CommissionerUnited States Tax Court · 1980
- Hundley v. CommissionerUnited States Tax Court · 1967
- Putnam v. CommissionerUnited States Tax Court · 1998
- Godfrey v. CommissionerUnited States Tax Court · 1963
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