Legal Opinion

Bennett's Travel Bureau, Inc. v. Commissioner

United States Tax Court

Decided November 25, 1957No. Docket No. 54126PublishedCited by 29 opinions

1. Petitioner, an American travel bureau, was controlled by Bennett's Reisebureau A/S, Oslo, Norway, hereinafter called Bennett's Oslo. Petitioner's operations included arranging trips for tourists to European countries. Petitioner's patrons normally paid petitioner in advance and were issued certificates covering hotel and transportation accommodations which were honored by its business associates, including Bennett's Oslo, through which the arrangements were contracted.

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1. Petitioner, an American travel bureau, was controlled by Bennett's Reisebureau A/S, Oslo, Norway, hereinafter called Bennett's Oslo. Petitioner's operations included arranging trips for tourists to European countries. Petitioner's patrons normally paid petitioner in advance and were issued certificates covering hotel and transportation accommodations which were honored by its business associates, including Bennett's Oslo, through which the arrangements were contracted. When the charges had been paid by Bennett's Oslo or other such associates, the amounts were billed by them to petitioner.…

1Opinion of the Court

Fishee, Judge:

This proceeding involves a deficiency in income tax determined against petitioner in the amount of $13,516.47 for the taxable year ended December 31,1949.

The issues presented for our consideration are (1) whether petitioner realized ordinary gain in the amount of $25,077.61 in 1949, upon the discharge of an indebtedness to Bennett’s Oslo by the payment of the obligation in kroner after the devaluation of the krone; and (2) whether the amounts of $2,575.61 and $207.34 representing reimbursement of travel and entertainment expense and compensation to Krogh, manager of Bennett’s…

2Cases cited13 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Gregory v. HelveringSupreme Court of the United States · 1935
  4. Helvering v. GowranSupreme Court of the United States · 1937
  5. Helvering v. GregoryCourt of Appeals for the Second Circuit · 1934

8 more not listed; retrieve them via the Exa API.

3Cited by29 opinions

  1. Estate of Beck v. Comm'rUnited States Tax Court · 1971
  2. Hynes v. CommissionerUnited States Tax Court · 1980
  3. Chapman v. CommissionerUnited States Tax Court · 1967
  4. American Air Filter Co. v. CommissionerUnited States Tax Court · 1983
  5. National-Standard Co. v. CommissionerUnited States Tax Court · 1983

24 more not listed; retrieve them via the Exa API.

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