Motto v. Commissioner
United States Tax Court
Held, fee expended to secure employment is deductible as an ordinary and necessary business expense within the meaning of sec. 162, I.R.C. 1954. David J. Primuth, 54 T.C. 374 (1970).
1Opinion of the Court
opinion
The petitioner expended $2,322.61 in 1967 and $399.36 in 1968, as employment fees and related expenses, in order to obtain new employment. He deducted the sum of these amounts on his income tax return for the year ended December 31, 1967. We must, now, determine whether the respondent has erred in disallowing this deduction.
Section 162(a) provides as follows:
SEO. 162. TRADE OR BUSINESS EXPENSES.(a) In Genebau. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business * * *
We hold that…
2Cases cited1 opinion
- Primuth v. CommissionerUnited States Tax Court · 1970
3Cited by22 opinions
- Cremona v. CommissionerUnited States Tax Court · 1972
- Jordan v. CommissionerUnited States Tax Court · 1973
- Kenfield v. CommissionerUnited States Tax Court · 1970
- Briggs v. CommissionerUnited States Tax Court · 1980
- Dietrich v. CommissionerUnited States Tax Court · 1971
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