Legal Opinion

Stemkowski v. Commissioner

United States Tax Court

Decided May 31, 1984No. Docket No. 4239-75PublishedCited by 17 opinions

The Court of Appeals held that petitioner's off-season conditioning expenses are allowable to the extent that they contribute to his fitness throughout the regular hockey season and directed us to decide which expenses were deductible under sec. 162, I.R.C. 1954. Held, none are deductible due to lack of substantiation.

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The Court of Appeals held that petitioner's off-season conditioning expenses are allowable to the extent that they contribute to his fitness throughout the regular hockey season and directed us to decide which expenses were deductible under sec. 162, I.R.C. 1954. Held, none are deductible due to lack of substantiation. In addition, the Court of Appeals directed us to decide whether petitioner's expenses in answering fan mail and purchasing Hockey News are deductible under sec. 162. Held, both of these expenses are deductible.

1Opinion of the Court

SUPPLEMENTAL OPINION

Goffe, Judge:

On February 17,1981, we filed our Opinion in the consolidated case of Peter Stemkowski and John J. Hanna v. Commissioner of Internal Revenue which is reported at 76 T.C. 252 (1981). We entered a decision in the Stemkowski case on July 8,1981, and on October 5,1981, petitioner Stemkowski filed a notice of appeal of our decision to the U.S. Court of Appeals for the Second Circuit.

On December 2, 1982, we filed the judgment of the Court of Appeals in which it affirmed in part and reversed and remanded in part our decision as to petitioner Stemkowski.

The Court of…

2Cases cited6 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
  4. Lloyd U. Noland, Jr., and Jane K. Noland v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1959
  5. Peter Stemkowski v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1982

1 more not listed; retrieve them via the Exa API.

3Cited by17 opinions

  1. Ronnen v. CommissionerUnited States Tax Court · 1988
  2. Robert M. Brown v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1990
  3. Favell v. United StatesUnited States Court of Claims · 1989
  4. Favell v. United StatesUnited States Court of Claims · 1990
  5. John J. Hanna v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985

12 more not listed; retrieve them via the Exa API.

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