Fife v. Commissioner
United States Tax Court
During 1974, petitioners paid a "utility users tax" imposed by the city of Seal Beach, Calif., at the rate of 5 percent of the charges they paid for gas, electric, and certain telephone utilities. Held, the amount of such tax paid by petitioners is not deductible under sec. 164, I.R.C. 1954, either as a local real property tax or as a local general sales tax.
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During 1974, petitioners paid a "utility users tax" imposed by the city of Seal Beach, Calif., at the rate of 5 percent of the charges they paid for gas, electric, and certain telephone utilities. Held, the amount of such tax paid by petitioners is not deductible under sec. 164, I.R.C. 1954, either as a local real property tax or as a local general sales tax. Petitioner-husband, an attorney, incurred the expense of his own morning, evening, or weekend meals on days when meetings with clients outside of regular business hours made eating those meals at his home inconvenient. Held, the cost of…
1Opinion of the Court
Phillip K. Fife and Kathleen M. Fife, Petitioners v. Commissioner of Internal Revenue, Respondent
Fife v. Commissioner
Docket No. 6441-78
United States Tax Court
73 T.C. 621; 1980 U.S. Tax Ct. LEXIS 210;
January 2, 1980, Filed
Decision will be entered for the respondent.
During 1974, petitioners paid a "utility users tax" imposed by the city of Seal Beach, Calif., at the rate of 5 percent of the charges they paid for gas, electric, and certain telephone utilities. Held, the amount of such tax paid by petitioners is not deductible under sec. 164, I.R.C. 1954, either as a local real property tax or as…
2Cases cited8 opinions
- United States v. CorrellSupreme Court of the United States · 1967
- Sutter v. CommissionerUnited States Tax Court · 1953
- Drill v. CommissionerUnited States Tax Court · 1947
- Lee E. Coombs and Judy B. Coombs v. Commissioner of Internal Revenue, James C. Cox v. United StatesCourt of Appeals for the Ninth Circuit · 1979
- Robert H. Saunders v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1954
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