Republic Engineers, Inc. v. Commissioner
United States Tax Court
Held, payment by petitioner to widow of deceased officer of predecessor corporation was not deductible as a business expense under sec. 162(a) and sec. 404(a)(5) ( sec. 1.404(a)-12, Income Tax Regs.).
1Opinion of the Court
OPINION
Quealy, Judge:
Respondent determined a deficiency in income tax of petitioner for the taxable year September 10, 1965, to June 80, 1966, in the amount of $618.41. The sole issue for decision relates to the deductibility of a payment of $2,000 made to the widow of a former officer of Utilities Engineering & Management Co. The petitioner acquired the assets and liabilities of that company.
The respondent contends that the payment in question did not constitute an ordinary and necessary business expense of the petitioner, and that its deductibility as a gift is limited to $25 under the…
2Cases cited2 opinions
- Interstate Drop Forge Company, a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1964
- Pacific Coast Steel Co. v. McLaughlinSupreme Court of the United States · 1933
3Cited by5 opinions
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- MSD INC. v. United StatesDistrict Court, N.D. Ohio · 1977
- Republic Engineers, Inc. v. CommissionerUnited States Tax Court · 1970