Ryman v. Commissioner
United States Tax Court
Facts: Petitioner, a full-time member of a law school faculty, expended amounts for admission to the bar of Iowa and for a reception held on the occasion of his admission to said bar. Petitioner deducted both amounts as ordinary and necessary business expenses pursuant to sec. 162(a), I.R.C. 1954. Held, the bar admission fee is a capital expenditure which is not deductible because the word "ordinary" in sec. 162(a) precludes a deduction for such expenditures.
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Facts: Petitioner, a full-time member of a law school faculty, expended amounts for admission to the bar of Iowa and for a reception held on the occasion of his admission to said bar. Petitioner deducted both amounts as ordinary and necessary business expenses pursuant to sec. 162(a), I.R.C. 1954. Held, the bar admission fee is a capital expenditure which is not deductible because the word "ordinary" in sec. 162(a) precludes a deduction for such expenditures. Held, further, the primary motivation for the reception was personal rather than business; hence, sec. 262, I.R.C. 1954, precludes any…
1Opinion of the Court
Irwin, Judge:
Respondent determined a deficiency in petitioners’ income tax for the taxable year 1963 in the amount of $66.69. The only issues for our decision'are whether or not petitioners are entitled to deduct as ordinary and necessary business expenses under section 1621 (1) amounts expended by petitioner Arthur E. Ryman, Jr., in gaining admission to practice before the bar of Iowa, and (2) the cost of a reception held on the occasion of petitioner Arthur E. Ryman’s admission to said bar.
FINDING OF FACT
Some of the facts have been stipulated, and the stipulation of facts, together with the…
2Cases cited9 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. LudeySupreme Court of the United States · 1927
- Commissioner v. TellierSupreme Court of the United States · 1966
- 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
- Chapman v. CommissionerUnited States Tax Court · 1967
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