Yeomans v. Commissioner
United States Tax Court
Petitioner, an industrial or consulting engineer, incorporated his business in 1922 after a number of years of individual operation. In the taxable years 1940 and 1941 he either owned or controlled nearly all the corporation's stock and received practically all its net earnings. Petitioner traveled extensively and did considerable entertaining.
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Petitioner, an industrial or consulting engineer, incorporated his business in 1922 after a number of years of individual operation. In the taxable years 1940 and 1941 he either owned or controlled nearly all the corporation's stock and received practically all its net earnings. Petitioner traveled extensively and did considerable entertaining. He withdrew sums of money from the corporation and expended them, both in and out of Chicago, his home and the business address of the corporation, for what he considered necessary to promote, develop, and maintain business. He personally kept no…
1Opinion of the Court
OPINION.
Arundell, Judge:
Respondent has treated as additional income to petitioner certain sums withdrawn by petitioner from the corporation, Lucien I. Yeomans, Inc., in 1940 and 1941, which sums were included in deductions taken by the corporation for business expenses in its returns for those years. In making his determination, respondent relied upon section 22 (a) of the Internal Revenue Code, defining “gross income,” and section 19.23 (a)-2 (b) of Regulations 103.1
We think respondent has acted properly in including such sums in petitioner’s income. Petitioner is an industrial or consulting…
2Cited by17 opinions
- O'Meara v. CommissionerUnited States Tax Court · 1947
- Riss & Co. v. CommissionerUnited States Tax Court · 1964
- Belser v. CommissionerUnited States Tax Court · 1948
- Hempel v. CommissionerUnited States Tax Court · 1947
- Campbell v. CommissionerUnited States Tax Court · 1961
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