Ihrig v. Commissioner
United States Tax Court
Petitioner, officer-stockholder of corporations without current resources, having paid corporate expenses to forestall enforced corporate liquidations and so avoid secondary personal liabilities, held not entitled to deductions as business expenses; held, further, additions to tax under section 291 (a), Internal Revenue Code of 1939, properly imposed.
1Opinion of the Court
OPINION.
OppeR, Judge:
Petitioner, an officer-stockholder of two corporations which lacked cash to meet current expenses, paid certain corporate expenses to keep the corporations alive. The-claimed benefit to him was to forestall enforced closings of the businesses and thus avoid personal liabilities which might otherwise be imposed upon him as a stockholder and surety or guarantor. He seeks- to justify his deduction of these payments as expenses incurred by him in carrying on a trade or business. Petitioner’s payments were primarily those required in the current operation of the business and…
2Cases cited7 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
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- Burnet v. ClarkSupreme Court of the United States · 1932
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