Cremona v. Commissioner
United States Tax Court
The taxpayer was employed as an "administrator." In 1968, he engaged the services of a job-counseling organization for a flat fee of $ 1,500 to assist him in obtaining a better job. The taxpayer did not succeed in obtaining any offers of employment as a result of such services and remained employed at his old job. Held, the fee paid by the taxpayer is deductible as an ordinary and necessary business expense. Sec. 162(a), I.R.C. 1954.
1Opinion of the Court
Queay, Judge:
The respondent determined a deficiency in income tax due from the petitioner in the amount of $572.80 for the taxable year 1968. All adjustments of income giving rise to the deficiency have been agreed to by the parties except for the disallowance by the respondent of the deduction of $1,500 paid by Leonard F. Cremona to a job-counseling organization in 1968.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts and exhibits attached thereto are incorporated herein by this reference.
Leonard F. Cremona and Marie Cremona are husband and wife whose legal…
Also in this document: Concurrence.
2Cases cited3 opinions
- Primuth v. CommissionerUnited States Tax Court · 1970
- Motto v. CommissionerUnited States Tax Court · 1970
- Carter v. CommissionerUnited States Tax Court · 1969
3Cited by52 opinions
- Nichols v. CommissionerUnited States Tax Court · 1973
- Estate of Rockefeller v. CommissionerUnited States Tax Court · 1984
- Black v. CommissionerUnited States Tax Court · 1973
- Jordan v. CommissionerUnited States Tax Court · 1973
- Estate of Rockefeller v. CommissionerCourt of Appeals for the Second Circuit · 1985
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