Kenfield v. Commissioner
United States Tax Court
T, an engineer employed by X corporation, made payments to Frederick Chusid & Co. to assist him in obtaining a new job as an engineer with increased compensation. As a result of Chusid's assistance T accepted a new job with Y corporation, but, prior to commencing work at the new job, X corporation in order to induce T to remain offered him a promotion with increased compensation.
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T, an engineer employed by X corporation, made payments to Frederick Chusid & Co. to assist him in obtaining a new job as an engineer with increased compensation. As a result of Chusid's assistance T accepted a new job with Y corporation, but, prior to commencing work at the new job, X corporation in order to induce T to remain offered him a promotion with increased compensation. T thereupon decided to remain with X. T's promotion at X was a direct consequence of his acceptance of the new job at Y. Held, T's payments to Chusid are deductible as ordinary and necessary business expenses. Sec.…
1Opinion of the Court
Kenneth R. Kenfield, Petitioner v. Commissioner of Internal Revenue, Respondent
Kenfield v. Commissioner
Docket No. 5289-68
United States Tax Court
54 T.C. 1197; 1970 U.S. Tax Ct. LEXIS 127;
June 3, 1970, Filed
Decision will be entered for the petitioner.
T, an engineer employed by X corporation, made payments to Frederick Chusid & Co. to assist him in obtaining a new job as an engineer with increased compensation. As a result of Chusid's assistance T accepted a new job with Y corporation, but, prior to commencing work at the new job, X corporation in order to induce T to remain offered him a…
2Cases cited4 opinions
- Primuth v. CommissionerUnited States Tax Court · 1970
- Motto v. CommissionerUnited States Tax Court · 1970
- Carson J. Morris and Muriel F. Morris v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
- Kenfield v. CommissionerUnited States Tax Court · 1970