Brown v. Commissioner
United States Tax Court
Petitioner operated a tutoring service for persons with learning disabilities. He rented an office. He later rented another office on a five-year lease and renovated it. He incurred telephone, promotion and transportation expenses in developing a computer monitoring program.
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Petitioner operated a tutoring service for persons with learning disabilities. He rented an office. He later rented another office on a five-year lease and renovated it. He incurred telephone, promotion and transportation expenses in developing a computer monitoring program. Held, (1) petitioner is entitled to deduct under section 162, I.R.C. 1954, rental expenses paid for use of his 16th Street office; (2) costs of renovating his leased New Hampshire Avenue office constitute capital expenditures under section 263; and (3) the telephone, promotion and transportation expenditures for the…
1Opinion of the Court
KENNETH AUSTIN BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Brown v. Commissioner
Docket No. 572-77.
United States Tax Court
T.C. Memo 1979-434; 1979 Tax Ct. Memo LEXIS 90; 39 T.C.M. (CCH) 397; T.C.M. (RIA) 79434;
October 24, 1979, Filed
Petitioner operated a tutoring service for persons with learning disabilities. He rented an office. He later rented another office on a five-year lease and renovated it. He incurred telephone, promotion and transportation expenses in developing a computer monitoring program. Held, (1) petitioner is entitled to deduct under section 162, I.R.C.…
2Cases cited17 opinions
- Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971
- Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
- Sharon v. CommissionerUnited States Tax Court · 1976
- Richmond Television Corp. v. United StatesSupreme Court of the United States · 1965
- Joel A. Sharon and Ann L. Sharon v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
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