Roland J. Hymel, Jr. And Mary Ann Hymel v. Commissioner of Internal Revenue

Appellants Roland J. Hymel, Jr., and Mary Ann Hymel appeal a Tax Court decision upholding a notice of deficiency issued to them by the Internal Revenue Service for the tax years 1978 and 1979. The Tax Court held that membership dues that Roland Hymel paid to a Mardi Gras carnival club were not ordinary and necessary business expenses deductible under 26 U.S.C. § 162(a) (1982). Because we find that the Tax Court improperly disregarded a stipulation agreed to by the parties, we reverse its decision and render judgment for the taxpayers.

I. Background

Roland Hymel is in the wholesale and retail…