Reuter v. Commissioner
United States Tax Court
Held, that petitioner is not entitled to deduct for income tax purposes, as an ordinary and necessary expense under either section 162 or section 212 of the 1954 Code, the amounts which he paid as additions to tax under section 6651(a) for the delinquent filing of a Federal excise tax return.
1Opinion of the Court
OPINION.
Pieece, Judge:
Respondent determined a deficiency in income tax against petitioner and his former wife for the calendar year 1957, in the amount of $2,295.12.
The sole issue for decision is whether the amounts which petitioner paid in the taxable year, as additions to tax for the late filing of a Federal manufacturer’s excise tax return, are deductible as an ordinary and necessary expense under either section 162 or section 212 of the income tax provisions of the 1954 Code.1
All of the facts have been stipulated. The stipulation of facts, including the exhibit attached thereto, is…
2Cases cited8 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Higgins v. SmithSupreme Court of the United States · 1940
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- McDonald v. CommissionerSupreme Court of the United States · 1944
- Tank Truck Rentals, Inc. v. CommissionerSupreme Court of the United States · 1958
3 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Uhlenbrock v. CommissionerUnited States Tax Court · 1977
- May v. CommissionerUnited States Tax Court · 1976
- Lafayette Extended Care, Inc. v. CommissionerUnited States Tax Court · 1978
- May v. CommissionerUnited States Tax Court · 1976
- Reuter v. CommissionerUnited States Tax Court · 1961
1 more not listed; retrieve them via the Exa API.