Forbes v. Commissioner
United States Tax Court
Section 23 (a) (2) -- Nonbusiness Expense Deduction -- Proximate Relation. -- Held, a payment of $ 1,000 made by the petitioner to the Investors League, Inc., in 1946, is not a deductible nonbusiness expense under section 23 (a) (2), where there is no proximate relation of the expenditure to the production or collection of petitioner's income or the management, conservation, or maintenance of income producing property of the petitioner.
1Opinion of the Court
OPINION.
Hakron, Judge:
This issue is whether or not a payment in the amount of $1,000 made by the petitioner to the Investors League, Inc., in 1946 is a nonbusiness expense deductible under section 23 (a) (2) of the Code.
The petitioner contends that the payment made to the League was an ordinary and necessary expense for the production of income or for the management and conservation of his stocks and bonds. The respondent argues that the payment did not have any relation to the production or collection of the petitioner’s income which he received from his securities or which was a result of…
2Cases cited14 opinions
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
- Textile Mills Securities Corp. v. CommissionerSupreme Court of the United States · 1941
- Old Mission Portland Cement Co. v. HelveringSupreme Court of the United States · 1934
- Leslie v. CommissionerUnited States Tax Court · 1946
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3Cited by3 opinions
- Fairman v. CommissionerUnited States Tax Court · 1964
- Forbes v. CommissionerUnited States Tax Court · 1952
- Mann v. CommissionerUnited States Tax Court · 1965