Rutz v. Commissioner
United States Tax Court
Petitioner kept receipts and monthly summaries of expenses for gifts, entertainment, meals, and boat operations and depreciation, but the business purpose of the expenditures and the business relationship to petitioner of the persons entertained were not included in such records. Petitioner's uncorroborated testimony as to business purpose and business relationship was insufficient to establish these elements.
Read the full summary
Petitioner kept receipts and monthly summaries of expenses for gifts, entertainment, meals, and boat operations and depreciation, but the business purpose of the expenditures and the business relationship to petitioner of the persons entertained were not included in such records. Petitioner's uncorroborated testimony as to business purpose and business relationship was insufficient to establish these elements. Held, the claimed deductions were not substantiated as required by sec. 274(d), I.R.C. 1954, and were properly disallowed.
1Opinion of the Court
Forrester, Judge:
Respondent has determined deficiencies in petitioner’s Federal income tax for the taxable years 1971 and 1972 in the amounts of $1,682.65 and $2,136.54, respectively. The sole issue presented for our decision is whether certain claimed deductions for gifts, entertainment, meals, boat operations, and depreciation should be disallowed under the provisions of section 274.1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner Frank Paul Rutz, unmarried during 1971 and 1972, resided in Portland, Oreg., at the time he filed the petition herein. He filed…
2Cases cited12 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Sanford v. CommissionerUnited States Tax Court · 1968
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Ashby v. CommissionerUnited States Tax Court · 1968
- Nicholls, North, Buse Co. v. CommissionerUnited States Tax Court · 1971
7 more not listed; retrieve them via the Exa API.
3Cited by35 opinions
- Berkley MacHine Works & Foundry Company v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1980
- Gilman v. CommissionerUnited States Tax Court · 1979
- MANNING v. COMMISSIONERUnited States Tax Court · 1993
- Concord Instruments Corp. v. CommissionerUnited States Tax Court · 1994
- Finney v. CommissionerUnited States Tax Court · 1980
30 more not listed; retrieve them via the Exa API.