Sutter v. Commissioner
United States Tax Court
Cost of meals and entertainment of petitioner or his family not shown to be greater or different than other personal expenses held denied deductibility as business expense by section 24 (a) (1), Internal Revenue Code, notwithstanding some connection with business occasions or entertainment.
1Opinion of the Court
OPINION.
Opper, Judge:
While the sole issue is deductibility as business expense of a number of items claimed by petitioner, the purposes of the expenditures and the grounds of their disallowance place them in separate categories and require individual disposition for each class. Of the seven types of items for which deductions were claimed we have concluded that five should be disallowed, entirely and that the other two are deductible only to a limited extent.
Running through most of the contested items is the stubborn thread of a single problem which has never apparently been squarely and…
2Cases cited2 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Home Guaranty Abstract Co. v. CommissionerUnited States Tax Court · 1947
3Cited by83 opinions
- George Harvey James v. United StatesCourt of Appeals for the Ninth Circuit · 1962
- Stolk v. CommissionerUnited States Tax Court · 1963
- Henry v. CommissionerUnited States Tax Court · 1961
- United Aniline Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1963
- Ma-Tran Corp. v. CommissionerUnited States Tax Court · 1978
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