Kahn v. Commissioner
United States Tax Court
Held, taxpayer's personal expenditure for entertainment of customers of a corporation in which he was a substantial stockholder, was not allowable as a business deduction under section 23 (a) (1) (A), I. R. C. 1939, or as a nontrade or nonbusiness deduction under section 23 (a) (2), I. R. C. 1939, and this was true even though he was also a creditor of the corporation and the guarantor of the other stockholder against loss.
1Opinion of the Court
OPINION.
Mulkoney, Judge:
Respondent determined a deficiency in income tax for the year 1949 in the sum of $871.90. Harry Kahn, hereinafter called the petitioner, and Emma Y. Kahn, are husband and wife. They reside in New York City and they filed their joint income tax return for the year 1949 with the collector of internal revenue for the second district of New York.
The entire deficiency arises by reason of respondent’s disallowance of a deduction of $2,108.12, which was money expended by petitioner in entertaining customers of Bernheimer & Brothers, Inc., a textile corporation in which…
2Cases cited3 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Kaplan v. CommissionerUnited States Tax Court · 1953
- Low v. NunanCourt of Appeals for the Second Circuit · 1946
3Cited by27 opinions
- Markwardt v. CommissionerUnited States Tax Court · 1975
- Hewett v. CommissionerUnited States Tax Court · 1967
- Leamy v. CommissionerUnited States Tax Court · 1985
- Rand v. CommissionerUnited States Tax Court · 1961
- R. Walter Graham and Dorothy H. Graham v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1964
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