Phelon v. Commissioner
United States Tax Court
In 1958 P was commissioned by the Springfield Library and Museums Association to procure a large male elephant for mounting and display at its Museum of Natural History. P, after obtaining a ruling from respondent permitting him to deduct transportation costs, meals and lodging, and the expenses of mounting and shipping the specimen to the Museum, made a safari to Africa and procured a large elephant, called "Suicide Sam."
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In 1958 P was commissioned by the Springfield Library and Museums Association to procure a large male elephant for mounting and display at its Museum of Natural History. P, after obtaining a ruling from respondent permitting him to deduct transportation costs, meals and lodging, and the expenses of mounting and shipping the specimen to the Museum, made a safari to Africa and procured a large elephant, called "Suicide Sam." On June 11, 1959, P executed a personal contract with J, a taxidermist, in which P agreed to pay J $20,000 for mounting the elephant. On April 1, 1960, P created P…
1Opinion of the Court
Russell E. Phelon and Jean G. Phelon v. Commissioner.
Phelon v. Commissioner
Docket No. 3299-64.
United States Tax Court
T.C. Memo 1966-199; 1966 Tax Ct. Memo LEXIS 86; 25 T.C.M. (CCH) 1024; T.C.M. (RIA) 66199;
September 12, 1966
In 1958 P was commissioned by the Springfield Library and Museums Association to procure a large male elephant for mounting and display at its Museum of Natural History. P, after obtaining a ruling from respondent permitting him to deduct transportation costs, meals and lodging, and the expenses of mounting and shipping the specimen to the Museum, made a safari to Africa…
2Cases cited11 opinions
- Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947
- Irving Sachs v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1960
- Sachs v. CommissionerUnited States Tax Court · 1959
- Elizabeth N. B. Ferro v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1957
- Monroe Zipp and Helen Zipp v. Commissioner of Internal Revenue, Bernard Zipp and Jean B. Zipp v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1958
6 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Palmer v. CommissionerUnited States Tax Court · 1974
- Palmer v. CommissionerUnited States Tax Court · 1974