Legal Opinion

Sutherland Lumber-Southwest, Inc. v. Commissioner

United States Tax Court

Decided March 28, 2000No. 23936-97Published

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

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
  3. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  4. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
  5. Naftel v. CommissionerUnited States Tax Court · 1985

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