Legal Opinion

Primuth v. Commissioner

United States Tax Court

Decided March 2, 1970No. Docket No. 3954-68PublishedCited by 278 opinions

Held, fee expended in order to secure employment is deductible as an ordinary and necessary business expense within the meaning of sec. 162, I.R.C. 1954.

1Opinion of the Court

OPINION

The petitioner seeks to deduct a fee of $3,016.43 which he paid in 1966 to Frederick Chusid & Co. for its services in securing new employment for him. We have found as a fact that Chusid at the outset virtually guaranteed him a new position and that their efforts did, in fact, result in Ms accepting a new position.

Section 162 (a) of the Code reads in part as follows:

SBC. 162. TRADE OR BUSINESS EXPENSES(a) In General. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, * * *

We hold…

2Cases cited16 opinions

  1. McDonald v. CommissionerSupreme Court of the United States · 1944
  2. Hochschild v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1947
  3. Mary O. Furner v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1968
  4. Schmidlapp v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1938
  5. Furner v. Comm'rUnited States Tax Court · 1966

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

3Cited by278 opinions

  1. Sharon v. CommissionerUnited States Tax Court · 1976
  2. Putoma Corp. v. CommissionerUnited States Tax Court · 1976
  3. O'Malley v. CommissionerUnited States Tax Court · 1988
  4. Keller v. CommissionerUnited States Tax Court · 1981
  5. Ford v. CommissionerUnited States Tax Court · 1971

273 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