Robinson v. Commissioner
United States Tax Court
Petitioner was a theatrical agent who during 1961, 1962, and 1963 visited bars and nightclubs in an effort to obtain contracts to represent entertainers and to sell talent to the clubs. He entertained the performers and buyers of talent. He traveled outside his home area in pursuit of his business. Petitioner used his house to some extent for entertaining and gave certain business gifts.
Read the full summary
Petitioner was a theatrical agent who during 1961, 1962, and 1963 visited bars and nightclubs in an effort to obtain contracts to represent entertainers and to sell talent to the clubs. He entertained the performers and buyers of talent. He traveled outside his home area in pursuit of his business. Petitioner used his house to some extent for entertaining and gave certain business gifts. Petitioner kept a regular set of books listing his income and expenses but did not keep supporting detailed records of his travel, entertainment, and gift expenses. Petitioner in 1961 paid over half the cost…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies in petitioner’s income taxes and additions to taxes under section 6653(a), I.R.C. 1954,1 for the calendar year 1961 in the amounts of $5,486.71 and $274.34, respectively; for the calendar year 1962 in the amounts of $7,190.95 and $359.55, respectively; and for the calendar year 1963 in the amounts of $5,256.82 and $262.84, respectively.
The issues for decision are:(1) Whether petitioner is entitled to deductions for the years 1961 and 1962 for travel and entertainment expenses of amounts in excess of the amounts allowed by respondent.(2) Whether…
2Cases cited11 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Sanford v. CommissionerUnited States Tax Court · 1968
- Commissioner v. BilderSupreme Court of the United States · 1962
- Reaver v. CommissionerUnited States Tax Court · 1964
- Griffith v. CommissionerUnited States Tax Court · 1961
6 more not listed; retrieve them via the Exa API.
3Cited by42 opinions
- Andress v. CommissionerUnited States Tax Court · 1969
- Grace v. CommissionerUnited States Tax Court · 1969
- Rutz v. CommissionerUnited States Tax Court · 1976
- Smith v. CommissionerUnited States Tax Court · 1976
- John Robinson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
37 more not listed; retrieve them via the Exa API.