Berkley MacHine Works & Foundry Company v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
1Opinion of the Court
JAMES DICKSON PHILLIPS, Circuit Judge:
The Commissioner of Internal Revenue appeals from a decision of the United States Tax Court, J. Gregory Bruce, Judge, allowing the taxpayer a deduction of some $100,000 for business entertainment expenses incurred in connection with a hunting and fishing facility it maintained on Ocracoke Island, North Carolina. Because we conclude that the claimed expenses, while undoubtedly business-related, do not meet the strict requirements of section 274 of the Internal Revenue Code of 1954 (as amended in 1962), and that taxpayer has not adequately substantiated the…
Also in this document: Dissent.
2Cases cited11 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Sanford v. CommissionerUnited States Tax Court · 1968
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Cam F. Dowell, Jr., Evelyn Dowell and Hillcrest State Bank, Plaintiffs v. United StatesCourt of Appeals for the Fifth Circuit · 1975
- BJR Corp. v. CommissionerUnited States Tax Court · 1976
6 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Meridian Wood Products Co., Inc., a Corporation v. United States of America, Harry F. Lenton and Colleen Lenton v. United StatesCourt of Appeals for the Ninth Circuit · 1984
- In Re Landbank Equity Corporation, a Virginia Corporation, Debtor. Internal Revenue Service v. Laurence H. Levy, Trustee, Debera F. ConlonCourt of Appeals for the Fourth Circuit · 1992
- Felver A. Rowell, Jr. And Betty C. Rowell v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1989
- Harrigan Lumber Co. v. CommissionerUnited States Tax Court · 1987
- Moore v. United StatesDistrict Court, E.D. Virginia · 1996
19 more not listed; retrieve them via the Exa API.