Worthy v. Commissioner
United States Tax Court
The petitioner received stock as part of an employment agreement. The stock was later redeemed. Held, the proceeds from the redemption constituted compensation. Held, further, the petitioners have failed to show that the use of a country club was primarily for business purposes within the meaning of sec. 274(a), I.R.C. 1954.
1Opinion of the Court
Simpson, Judge:
The respondent determined the following deficiencies in the petitioners’ Federal income taxes:
Year Deficiency
1967 _ $918.99
1968 _ 804.26
1969 _1, 001. 81
Due to concessions, two issues remain for consideration: We must first decide whether certain payments received in connection with the redemption of certain stock constituted additional compensation or capital gains. Second, we must decide whether the petitioner has shown that, within the meaning of section 274(a) of the Internal Revenue Code of 1954,1 he used his membership in a country club primarily for business purposes so…
2Cases cited12 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Commissioner v. SmithSupreme Court of the United States · 1945
- Coors v. CommissionerUnited States Tax Court · 1973
- Mathews v. CommissionerUnited States Tax Court · 1973
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3Cited by9 opinions
- Buddy Schoellkopf Products, Inc. v. CommissionerUnited States Tax Court · 1975
- Finney v. CommissionerUnited States Tax Court · 1980
- Fenstermaker v. CommissionerUnited States Tax Court · 1978
- Borom v. CommissionerUnited States Tax Court · 1980
- Buddy Schoellkopf Products, Inc. v. CommissionerUnited States Tax Court · 1975
4 more not listed; retrieve them via the Exa API.