Schultz v. Commissioner
United States Tax Court
Petitioner purchased raw whisky, distilled as bourbon, as an investment and, at the time of purchase, made payment in advance to the seller of 4 years of carrying charges, consisting of insurance, storage, and an amount equal to estimated State ad valorem taxes. The normal aging period of bourbon whisky is 4 years. Petitioner also expended certain sums in payment for certain legal services. Held, that petitioner's objective was to acquire 4-year bourbon whisky.
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Petitioner purchased raw whisky, distilled as bourbon, as an investment and, at the time of purchase, made payment in advance to the seller of 4 years of carrying charges, consisting of insurance, storage, and an amount equal to estimated State ad valorem taxes. The normal aging period of bourbon whisky is 4 years. Petitioner also expended certain sums in payment for certain legal services. Held, that petitioner's objective was to acquire 4-year bourbon whisky. Held, further, that the expenditures for carrying charges are not deductible expense under sec. 212(2), even on a prorated basis, and…
1Opinion of the Court
George L. Schultz and Margaret F. Schultz, Petitioners v. Commissioner of Internal Revenue, Respondent
Schultz v. Commissioner
Docket No. 4947-66
United States Tax Court
50 T.C. 688; 1968 U.S. Tax Ct. LEXIS 91;
July 31, 1968, Filed
Decision will be entered under Rule 50.
Petitioner purchased raw whisky, distilled as bourbon, as an investment and, at the time of purchase, made payment in advance to the seller of 4 years of carrying charges, consisting of insurance, storage, and an amount equal to estimated State ad valorem taxes. The normal aging period of bourbon whisky is 4 years. Petitioner also…
Also in this document: Dissent.
2Cases cited35 opinions
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Kapel Goldstein and Tillie Goldstein v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966
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