Andress v. Commissioner
United States Tax Court
Petitioner, a practicing attorney, claimed deductions for "courtesy and promotion" expenditures in 1964 and 1965, consisting of purchases of liquor used at social gatherings at his residence, the payment of dues, food, and drinks at two private clubs, and certain undesignated items.
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Petitioner, a practicing attorney, claimed deductions for "courtesy and promotion" expenditures in 1964 and 1965, consisting of purchases of liquor used at social gatherings at his residence, the payment of dues, food, and drinks at two private clubs, and certain undesignated items. Held, that the expenditures constitute "entertainment" expenses under sec. 274, I.R.C. 1954; that petitioner has failed to establish that the expenditures were directly related to the active conduct of his business as required by sec. 274(a)(1) and the regulations promulgated thereunder; and that petitioner has…
1Opinion of the Court
Dawson, Judge:
Respondent determined income tax deficiencies against the petitioners for the years 1964 and 1965 in the amounts of $1,614.61 and $727.40, respectively.
Certain adjustments made by respondent in the notice of deficiency have been resolved by agreement of the parties and can be given effect in the Rule 50 computation. The only issue for decision is whether petitioner Wm. Andress, Jr., a practicing attorney, is entitled to deduct amounts claimed as “courtesy and promotion” expenses on Federal income tax returns filed for the years 1964 and 1965.
FINDINGS OP PACT
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2Cases cited7 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Sanford v. CommissionerUnited States Tax Court · 1968
- Ashby v. CommissionerUnited States Tax Court · 1968
- Henry v. CommissionerUnited States Tax Court · 1961
- Boehm v. CommissionerUnited States Board of Tax Appeals · 1937
2 more not listed; retrieve them via the Exa API.
3Cited by51 opinions
- Cam F. Dowell, Jr., Evelyn Dowell and Hillcrest State Bank, Plaintiffs v. United StatesCourt of Appeals for the Fifth Circuit · 1975
- Wm. Andress, Jr., and Devona C. Andress v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1970
- Rutz v. CommissionerUnited States Tax Court · 1976
- Philip Handelman and Esther Handelman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1975
- Bussabarger v. CommissionerUnited States Tax Court · 1969
46 more not listed; retrieve them via the Exa API.