Legal Opinion

Walliser v. Commissioner

United States Tax Court

Decided June 7, 1979No. Docket No. 2368-77Published

Petitioner, a bank officer responsible for marketing loans, participated in vacation tours attended primarily by builders because social relationships with builders established on the tours generated loan business which helped petitioner meet his assigned loan production quotas and obtain increases in his salary. Held, expenditures for petitioner's vacation tours were ordinary and necessary business expenses.

Read the full summary

Petitioner, a bank officer responsible for marketing loans, participated in vacation tours attended primarily by builders because social relationships with builders established on the tours generated loan business which helped petitioner meet his assigned loan production quotas and obtain increases in his salary. Held, expenditures for petitioner's vacation tours were ordinary and necessary business expenses. Sec. 162(a)(2), I.R.C. 1954. Held, further, vacation tours constituted an "entertainment, amusement, or recreation" activity for purposes of sec. 274(a), I.R.C. 1954, and were subject to…

1Opinion of the Court

James B. Walliser and Carol Sue Walliser, Petitioners v. Commissioner of Internal Revenue, Respondent

Walliser v. Commissioner

Docket No. 2368-77

United States Tax Court

72 T.C. 433; 1979 U.S. Tax Ct. LEXIS 106;

June 7, 1979, Filed

Decision will be entered for the respondent.

Petitioner, a bank officer responsible for marketing loans, participated in vacation tours attended primarily by builders because social relationships with builders established on the tours generated loan business which helped petitioner meet his assigned loan production quotas and obtain increases in his salary. Held,…

2Cases cited12 opinions

  1. Commissioner v. HeiningerSupreme Court of the United States · 1943
  2. Stolk v. CommissionerUnited States Tax Court · 1963
  3. Walliser v. CommissionerUnited States Tax Court · 1979
  4. Henry v. CommissionerUnited States Tax Court · 1961
  5. Marvin A. Heidt and Beatrice Heidt v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1959

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

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API