Sutherland Lumber-Southwest, Inc. v. Commissioner
United States Tax Court
P provided its employees with the use of the company-owned aircraft for nonbusiness flights. P notified its employees to report the value of the flights as imputed income. P deducted the expenses incurred in providing the flights. R, relying on sec. 274(e)(2), I.R.C., determined that deductions for expenses incurred in providing employees with nonbusiness flights on a company-owned airplane are limited to the amount reported as imputed income to the recipient employees.
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P provided its employees with the use of the company-owned aircraft for nonbusiness flights. P notified its employees to report the value of the flights as imputed income. P deducted the expenses incurred in providing the flights. R, relying on sec. 274(e)(2), I.R.C., determined that deductions for expenses incurred in providing employees with nonbusiness flights on a company-owned airplane are limited to the amount reported as imputed income to the recipient employees. P contends that its expense deductions are not subject to sec. 274, I.R.C., or, in the alternative, if subject to sec. 274,…
1Opinion of the Court
SUTHERLAND LUMBER-SOUTHWEST, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sutherland Lumber-Southwest, Inc. v. Commissioner
No. 23936-97
United States Tax Court
114 T.C. 197; 2000 U.S. Tax Ct. LEXIS 17; 114 T.C. No. 14; 24 Employee Benefits Cas. (BNA) 2358;
March 28, 2000, Filed
An appropriate order will be issued.
P provided its employees with the use of the company-owned
aircraft for nonbusiness flights. P notified its employees to
report the value of the flights as imputed income. P deducted
the expenses incurred in providing the flights. R, relying on
sec. 274(e)(2), I.R.C.,…
2Cases cited15 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Naftel v. CommissionerUnited States Tax Court · 1985
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