William F. Sanford v. Commissioner of Internal Revenue

Taxpayer, an “outside salesman” for RKO, deducted on his federal income tax return for the year 1963 items of non-reimbursed entertainment expense totaling $5,667.17. The Commissioner disallowed the deduction taken for any of these alleged entertainment expenditures if in excess of $25.00, and allowed the alleged non-reimbursed entertainment expenses that were less than $25.00. The latter figure amounted to $682.86. The former figure totaled $4,984.31, and the dispute here relates to the disallowance of the $4,984.31. The Commissioner disallowed these deductions taken for expenses in excess…