Hartless Linen Service Co. v. Commissioner
United States Tax Court
Held, payments made by petitioner to various Christian Science churches and societies during 1953 and 1954 do not constitute ordinary and necessary business expenses under section 23(a)(1)(A), I.R.C. 1939, and section 162(a), I.R.C. 1954, but represent charitable contributions within the meaning of section 23(q), I.R.C. 1939, and section 170(a), I.R.C. 1954.
1Opinion of the Court
Withey, Judge:
The respondent determined deficiencies in the petitioner’s income tax for the years and in the amounts as follows:
Tear Amount
1953 _$4,120.12
1954 _ 2, 876. 21
The sole issue presented for our decision is the correctness of the respondent’s action in determining that the contributions made by the petitioner to Christian Science churches and societies during 1953 and 1954 are not deductible as ordinary and necessary business expenses under section 23(a) of the Internal Revenue Code of 1939 and section 162(a) of the Internal Revenue Code of 1954. The respondent has determined that…
2Cases cited1 opinion
- Wm. T. Stover Co. v. CommissionerUnited States Tax Court · 1956
3Cited by8 opinions
- Singer Co. v. United StatesUnited States Court of Claims · 1971
- Marquis v. CommissionerUnited States Tax Court · 1968
- The Singer Company v. The United StatesUnited States Court of Claims · 1971
- Hartless Linen Service Co. v. CommissionerUnited States Tax Court · 1959
- Marquis v. CommissionerUnited States Tax Court · 1968
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