Pepper v. Commissioner
United States Tax Court
Deduction -- Ordinary and Necessary Business Expense -- Payments Made To Protect Taxpayer's Trade or Business -- Sec. 23(a) (1)(A), 1939 Code. -- Petitioners were engaged in a partnership organized for the general practice of law. During the latter part of 1952, David K. Spiegel, an associate professor of economics, retained petitioners to assist him in securing financing for his plastic housewares jobbing business.
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Deduction -- Ordinary and Necessary Business Expense -- Payments Made To Protect Taxpayer's Trade or Business -- Sec. 23(a) (1)(A), 1939 Code. -- Petitioners were engaged in a partnership organized for the general practice of law. During the latter part of 1952, David K. Spiegel, an associate professor of economics, retained petitioners to assist him in securing financing for his plastic housewares jobbing business. In addition to securing lenders for David's business, petitioners also drew up assignments and other legal instruments. During the time petitioners represented David and his…
1Opinion of the Court
Train, Judge:
Respondent determined deficiencies in petitioners’ income tax liability for the calendar years 1953 and 1954 as follows:
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The issue for determination is:(1) Whether certain payments are deductible as ordinary and necessary business expenses;(2) Alternatively, whether the payments are deductible as a loss incurred in a trade or business;(3) Alternatively, whether the payments are deductible as debts incurred in a trade or business; or(4) Alternatively, whether the payments are deductible as a non-business bad debt.
FINDINGS OK PACT.
Some of the facts have been stipulated…
2Cases cited11 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Snow v. CommissionerUnited States Tax Court · 1958
- Dinardo v. CommissionerUnited States Tax Court · 1954
- L. Heller & Son, Inc. v. CommissionerUnited States Tax Court · 1949
- Scruggs-Vandervoort-Barney, Inc. v. CommissionerUnited States Tax Court · 1946
6 more not listed; retrieve them via the Exa API.
3Cited by53 opinions
- Centel Communications Co. v. CommissionerUnited States Tax Court · 1989
- Gould v. CommissionerUnited States Tax Court · 1975
- Pike v. CommissionerUnited States Tax Court · 1965
- Hood v. CommissionerUnited States Tax Court · 2000
- Rafter v. CommissionerUnited States Tax Court · 1973
48 more not listed; retrieve them via the Exa API.