Legal Opinion

Epp v. Commissioner

United States Tax Court

Decided May 12, 1982No. Docket No. 12740-79Published

P paid $ 2,000 to the Institute of Individual Religious Studies for information, guidance, and written materials to be used to establish a family estate trust. Subsequently, P established and transferred assets to such a trust. Held, P failed to prove that any part of such payment was an ordinary and necessary expenditure paid for the management, conservation, or maintenance of property held for the production of income or for tax advice. Sec. 212(2) and ( 3), I.R.C. 1954.

1Opinion of the Court

Susan H. Epp, Petitioner v. Commissioner of Internal Revenue, Respondent

Epp v. Commissioner

Docket No. 12740-79

United States Tax Court

78 T.C. 801; 1982 U.S. Tax Ct. LEXIS 99; 78 T.C. No. 55;

May 12, 1982, Filed

P paid $ 2,000 to the Institute of Individual Religious Studies for information, guidance, and written materials to be used to establish a family estate trust. Subsequently, P established and transferred assets to such a trust. Held, P failed to prove that any part of such payment was an ordinary and necessary expenditure paid for the management, conservation, or maintenance of property…

2Cases cited25 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. W. Horace Williams, Sr., and Viola Bloch Williams v. United StatesCourt of Appeals for the Fifth Circuit · 1957
  4. Brotherhood of Locomotive Engineers v. Louisville & Nashville RailroadSupreme Court of the United States · 1963
  5. Frank v. CommissionerUnited States Tax Court · 1953

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