Legal Opinion

Wright v. Commissioner

United States Tax Court

Decided March 31, 1959No. Docket No. 67973PublishedCited by 36 opinions

Petitioners, an attorney and his wife, took a trip around the world and wrote a daily narrative of their experiences and impressions, which they compiled in book form and unsuccessfully tried to publish. Held, the expenses of the trip and producing the manuscript for publication are not deductible as ordinary and necessary expenses of carrying on a trade or business under section 162(a), I.R.C. 1954.

1Opinion of the Court

Dkennen, Judge:

Respondent determined a deficiency in petitioners’ income tax for the calendar year 1954 of $2,914.28. The sole issue is whether the amount of $6,487.98 expended by petitioners for a trip around the world and subsequent attempts to publish a book about this trip should be allowed as a business deduction under section 162(a) of the Internal Revenue Code of 1954.

findings of fact.

Petitioners Kerns and Margaret Wright, hereinafter referred to as Kerns and Margaret, are and were during the year 1954 husband and wife and resided at Van Wert, Ohio. They filed joint income tax returns…

2Cases cited8 opinions

  1. Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
  2. Fahs v. CrawfordCourt of Appeals for the Fifth Circuit · 1947
  3. Walet v. CommissionerUnited States Tax Court · 1958
  4. Thacher v. LoweDistrict Court, S.D. New York · 1922
  5. Doggett v. BurnetCourt of Appeals for the D.C. Circuit · 1933

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3Cited by36 opinions

  1. Clement L. Hirsch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
  2. Fischer v. CommissionerUnited States Tax Court · 1968
  3. Jackson v. CommissionerUnited States Tax Court · 1986
  4. Johnsen v. CommissionerUnited States Tax Court · 1984
  5. Paul Snyder and Helen J. Snyder v. United StatesCourt of Appeals for the Tenth Circuit · 1982

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