Legal Opinion

Nguyen v. Commissioner

United States Tax Court

Decided August 19, 1993No. Docket Nos. 30600-91, 30601-91Unpublished

H and W ran a "shrimping" business. Respondent disallowed a deduction from the income of this business for commission expense for H's 1982 taxable year. Respondent also disallowed a similar deduction for the 1983 and 1984 taxable years of H and W. Respondent further determined that H and W had unreported income for the 1983 taxable year in the amount of $ 100,000. H and W claimed the source of the $ 100,000 was loans, most of which they did not substantiate.

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H and W ran a "shrimping" business. Respondent disallowed a deduction from the income of this business for commission expense for H's 1982 taxable year. Respondent also disallowed a similar deduction for the 1983 and 1984 taxable years of H and W. Respondent further determined that H and W had unreported income for the 1983 taxable year in the amount of $ 100,000. H and W claimed the source of the $ 100,000 was loans, most of which they did not substantiate. Held: Respondent's disallowance of commission expense is sustained for all years in issue. Held further: The 1983 taxable income of H…

1Opinion of the Court

PHUONG V. NGUYEN AND THU H. NGUYEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Nguyen v. Commissioner

Docket Nos. 30600-91, 30601-91

United States Tax Court

T.C. Memo 1993-369; 1993 Tax Ct. Memo LEXIS 382; 66 T.C.M. (CCH) 416;

August 19, 1993, Filed

Decision will be entered under Rule 155.

H and W ran a "shrimping" business. Respondent disallowed a deduction from the income of this business for commission expense for H's 1982 taxable year. Respondent also disallowed a similar deduction for the 1983 and 1984 taxable years of H and W. Respondent further determined that H and W had…

2Cases cited19 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  4. United States v. JanisSupreme Court of the United States · 1976
  5. Neely v. CommissionerUnited States Tax Court · 1985

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