Fenstermaker v. Commissioner
United States Tax Court
Petitioner-husbands are executives of a large electric utility company. Pursuant to its policy, the Company paid or reimbursed petitioners for their wives' expenses at annual trade association conventions. The business purpose for the conventions was the technical business meetings and lectures, not the social functions.
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Petitioner-husbands are executives of a large electric utility company. Pursuant to its policy, the Company paid or reimbursed petitioners for their wives' expenses at annual trade association conventions. The business purpose for the conventions was the technical business meetings and lectures, not the social functions. The wives provided no business connected services for their husbands at the conventions, and their attendance was unnecessary to their husbands' effectiveness there. Held: Petitioners must include their wives' convention expenses in gross income. Held further: Petitioners may…
1Opinion of the Court
JAMES P. FENSTERMAKER and MARGARET J. FENSTERMAKER, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Fenstermaker v. Commissioner
Docket Nos. 11066-76, 11067-76, 11068-76.
United States Tax Court
T.C. Memo 1978-210; 1978 Tax Ct. Memo LEXIS 307; 37 T.C.M. (CCH) 898; T.C.M. (RIA) 780210;
June 7, 1978, Filed
Petitioner-husbands are executives of a large electric utility company. Pursuant to its policy, the Company paid or reimbursed petitioners for their wives' expenses at annual trade association conventions. The business purpose for the conventions was the technical business…
2Cases cited36 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Dixon v. United StatesSupreme Court of the United States · 1965
- Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
- Commissioner v. JacobsonSupreme Court of the United States · 1949
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3Cited by2 opinions
- Elvia R. McCann and Mrs. Leone A. McCann v. The United States, Ms. Vertie M. Graves v. The United StatesCourt of Appeals for the Federal Circuit · 1983
- Russo v. CommissionerUnited States Tax Court · 1982