Heigerick v. Commissioner
United States Tax Court
Petitioner, an osteopathic doctor, paid $ 3,000 in 1960 for staff privilege fees in a hospital, which in effect, secured such staff privileges for him for an indefinite period extending well beyond the year of payment. Held, the expenditure was a capital outlay and not deductible in full as an ordinary and necessary business expense under section 162(a), I.R.C. 1954.
1Opinion of the Court
MulRoney, Judge:
Respondent determined a deficiency in petitioners’ income tax for the year 1960 in the amount of $1,654.17.
Glenn L. Heigerick, who will be called petitioner, is an osteopathic physician, and the issue is whether his payment in 1960 of $3,000 to a hospital is properly deductible in full in that year as a business expense.
BINDINGS OB BACT
Some of the facts have been stipulated and they are found accordingly.
Petitioner and his wife, Maureen Frances, live in Indian Hill, Ohio, and they filed their joint income tax return for the year 1960 with the district director of internal…
2Cases cited5 opinions
- United States v. Victor H. And Elsie Akin, Fred C. And Alice M. Kluver, E.F. And Gladys MunroeCourt of Appeals for the Tenth Circuit · 1957
- Kauai Terminal, Ltd. v. CommissionerUnited States Board of Tax Appeals · 1937
- Mercantile Nat'l Bank v. CommissionerUnited States Tax Court · 1958
- Commissioner of Internal Revenue v. Mercantile National Bank at DallasCourt of Appeals for the Fifth Circuit · 1960
- Grace National Bank of New York v. CommissionerUnited States Tax Court · 1950
3Cited by27 opinions
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- Hunter v. CommissionerUnited States Tax Court · 1966
- Cagle v. CommissionerCourt of Appeals for the Fifth Circuit · 1976
- First Sec. Bank, N.A. v. CommissionerUnited States Tax Court · 1975
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