Nicholls, North, Buse Co. v. Commissioner
United States Tax Court
Held: 1. Depreciation, operating expenses, and investment credit for a boat purchased with corporate funds are not deductible since corporation did not meet substantiation requirements of sec. 274. Once personal use of an entertainment facility is shown to have occurred, taxpayer must clearly prove the limit of such occasions. 2. The business identity of a guest using an entertainment facility is insufficient to circumstantially substantiate the business purpose of the…
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Held: 1. Depreciation, operating expenses, and investment credit for a boat purchased with corporate funds are not deductible since corporation did not meet substantiation requirements of sec. 274. Once personal use of an entertainment facility is shown to have occurred, taxpayer must clearly prove the limit of such occasions. 2. The business identity of a guest using an entertainment facility is insufficient to circumstantially substantiate the business purpose of the occasion of use for purposes of sec. 274(d). 3. Notwithstanding son's minority interest in corporation, taxpayer received a…
1Opinion of the Court
Withey, Judge:
Tbe respondent determined deficiencies in income tax against the corporate petitioner for the taxable years ended December 31, 1963, and December 31,1964, in tbe respective amounts of $299.16 and $2,260.11 and against tbe individual petitioners for the same years in the respective amounts of $388.91 and $36,359.62. The only issue affecting the year ended December 31,1963, for either petitioner has been settled by stipulation which will be given effect under Bule 50.
The issues remaining unresolved are first, whether respondent erred as to petitioner Nicholls, North, Buse Co. in…
2Cases cited17 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Sanford v. CommissionerUnited States Tax Court · 1968
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Challenge Mfg. Co. v. CommissionerUnited States Tax Court · 1962
- American Properties, Inc. v. CommissionerUnited States Tax Court · 1957
12 more not listed; retrieve them via the Exa API.
3Cited by58 opinions
- Pike v. CommissionerUnited States Tax Court · 1982
- Charles W. Ireland and Carolyn P. Ireland v. United StatesCourt of Appeals for the Fifth Circuit · 1980
- Brittingham v. CommissionerUnited States Tax Court · 1976
- Rutz v. CommissionerUnited States Tax Court · 1976
- Philip Handelman and Esther Handelman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1975
53 more not listed; retrieve them via the Exa API.