Trebilcock v. Commissioner
United States Tax Court
Petitioner, a sole proprietor, paid a minister $ 7,020 a year to give him and his employees spiritual advice and to perform various business-related tasks. Petitioner deducted that amount as an ordinary and necessary business expense under sec. 162(a), I.R.C. 1954. Held, only $ 1,000 of that amount, which constituted compensation for business-related tasks, is deductible.
1Opinion of the Court
Wiles, Judge:
Respondent determined deficiencies in petitioners’ income tax of $2,658 for 1969 and $2,914 for 1970. The issue is whether Lionel Trebilcock (hereinafter petitioner), a sole proprietor, may deduct under section 162(a)1 $7,020 he paid in each of those years to a minister who provided spiritual advice to petitioner and his employees and performed business-related tasks.
FINDINGS OF FACT
Petitioner and his wife, Shirley Trebilcock, resided in Girard, Ohio, when they filed joint 1969 and 1970 income tax returns with the District Director of Internal Revenue, Cleveland, Ohio, and when…
2Cases cited6 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Lilly v. CommissionerSupreme Court of the United States · 1952
- Fred W. Amend Co. v. CommissionerUnited States Tax Court · 1970
1 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Lionel F. Trebilcock and Shirley Trebilcock v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1977
- Hymel v. CommissionerUnited States Tax Court · 1985
- Pace v. Comm'rUnited States Tax Court · 2010
- Trebilcock v. CommissionerUnited States Tax Court · 1975