Jackson v. Commissioner
United States Tax Court
On December 21, 1982, petitioners paid $ 18,500 ($ 15,000 -- distributorship fee; $ 3,000 -- gemstones; $ 500 -- consulting fee) in connection with an arrangement assertedly to sell jewelry in certain geographic areas to which petitioners were to be assigned exclusive licenses. On their 1982 tax return, petitioners deducted $ 15,500 of these payments (the distributorship fee and the consulting fee). Held: (1) Petitioners are not entitled to their claimed deductions.
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On December 21, 1982, petitioners paid $ 18,500 ($ 15,000 -- distributorship fee; $ 3,000 -- gemstones; $ 500 -- consulting fee) in connection with an arrangement assertedly to sell jewelry in certain geographic areas to which petitioners were to be assigned exclusive licenses. On their 1982 tax return, petitioners deducted $ 15,500 of these payments (the distributorship fee and the consulting fee). Held: (1) Petitioners are not entitled to their claimed deductions. (2) Petitioners' deficiency is attributable to a tax-motivated transaction ( sec. 6621(c)(3)(A)(v), I.R.C. 1954 and 1986).
1Opinion of the Court
JOHN F. JACKSON, JR., and SHIRLEY JACKSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Jackson v. Commissioner
Docket No. 45345-85
United States Tax Court
T.C. Memo 1991-250; 1991 Tax Ct. Memo LEXIS 293; 61 T.C.M. (CCH) 2806; T.C.M. (RIA) 91250;
June 5, 1991, Filed
Decision will be entered for the respondent.
On December 21, 1982, petitioners paid $ 18,500 ($ 15,000 -- distributorship fee; $ 3,000 -- gemstones; $ 500 -- consulting fee) in connection with an arrangement assertedly to sell jewelry in certain geographic areas to which petitioners were to be assigned exclusive licenses.…
2Cases cited7 opinions
- Abramson v. CommissionerUnited States Tax Court · 1986
- Cherin v. CommissionerUnited States Tax Court · 1987
- Fox v. CommissionerUnited States Tax Court · 1984
- James v. CommissionerUnited States Tax Court · 1986
- Moore v. CommissionerUnited States Tax Court · 1985
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