Legal Opinion

Larrabee v. Commissioner

United States Tax Court

Decided February 9, 1960No. Docket No. 67725PublishedCited by 50 opinions

Expenses relating to ownership and operation of a yacht held not deductible from gross income as ordinary and necessary business expenses. Sec. 23(a), I.R.C. 1939.

1Opinion of the Court

OPINION.

Raum, Judge:

Petitioners contend that the cost of owning and operating the Goodwill during the year 1953 should be allowed as ordinary and necessary business expense incurred in carrying on the business of the L. & F. Machine Co., a business which was owned and operated by petitioner as sole proprietor. They urge that the Goodwill was used primarily for entertainment of business friends, potential customers, and others primarily for business reasons and with a view to profit, and that as a result the business of the L. & F. Machine Co. was increased during the year 1953. We do not…

2Cases cited3 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Walet v. CommissionerUnited States Tax Court · 1958
  3. Eugene H. Walet, Jr. And Celia R. Walet v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959

3Cited by50 opinions

  1. Challenge Mfg. Co. v. CommissionerUnited States Tax Court · 1962
  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. Reginald G. Hearn and Mary L. Hearn, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962

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