Legal Opinion

Brown v. Commissioner

United States Tax Court

Decided May 25, 1983No. Docket No. 2294-79Unpublished

During the taxable years in issue, petitioners deducted various expenses incurred incident to the promotion and development of a Theme Park. Held, such expenses were not proximately related to any trade or business carried on by petitioner Charles Brown or his wholly owned subchapter S corporation and, therefore, are not currently deductible under section 162, I.R.C. 1954.

1Opinion of the Court

CHARLES J. BROWN and NANCY G. BROWN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Brown v. Commissioner

Docket No. 2294-79.

United States Tax Court

T.C. Memo 1983-291; 1983 Tax Ct. Memo LEXIS 491; 46 T.C.M. (CCH) 233; T.C.M. (RIA) 83291;

May 25, 1983.

During the taxable years in issue, petitioners deducted various expenses incurred incident to the promotion and development of a Theme Park. Held, such expenses were not proximately related to any trade or business carried on by petitioner Charles Brown or his wholly owned subchapter S corporation and, therefore, are not currently…

2Cases cited18 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. Higgins v. CommissionerSupreme Court of the United States · 1941
  4. Whipple v. CommissionerSupreme Court of the United States · 1963
  5. Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965

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