Earl M. Coplon and Mollie M. Coplon v. Commissioner of Internal Revenue

Petitioners, husband and wife, deducted on their 1954 joint income tax return the sum of $4,755.61, claiming that such expenditures were “ordinary and necessary expenses paid or incurred during the taxable year” in carrying on the trade or business of Earl Coplon. The Commissioner of Internal Revenue disallowed the claimed deduction, asserting that the expenditures were not deductible under the provisions of Section 162 of the Internal Revenue Code of 1954, 26 U.S.C.A. § 162. The Tax Court affirmed the Commissioner, concluding that, “Earl Coplon had not carried his burden of showing that the…