X-Pando Corp. v. Commissioner
United States Tax Court
In 1937 new interests took over the ownership and management of petitioner, which was at that time carrying on a small manufacturing business. In that year and two subsequent years petitioner made heavy expenditures for the purpose of developing its business. Included in such expenditures were salaries of officers and employees, traveling expenses, rent, and advertising.
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In 1937 new interests took over the ownership and management of petitioner, which was at that time carrying on a small manufacturing business. In that year and two subsequent years petitioner made heavy expenditures for the purpose of developing its business. Included in such expenditures were salaries of officers and employees, traveling expenses, rent, and advertising. Petitioner allocated a part of these expenditures to current business expenses, which it deducted as such, and a part to an account called "Business Development Account." In 1941 petitioner began to amortize this account at…
1Opinion of the Court
OPINION.
Keen, Judge-.
The only question presented here is whether the respondent erred in disallowing the deduction claimed by the petitioner corporation in amortization of an account to which it had charged certain expenditures in earlier years which, it contends, were in the nature of capital expenditures. Respondent justifies his action on the ground that the items charged to the account were business expenses, deductible only in the year paid or accrued.
The items consisted of salaries, traveling expenses, rent, and advertising expenses. These, of course, are expenses of a type which are…
2Cases cited1 opinion
- Toledo Newspaper Co. v. CommissionerUnited States Tax Court · 1943
3Cited by24 opinions
- Michaels v. CommissionerUnited States Tax Court · 1949
- Consolidated Apparel Co. v. CommissionerUnited States Tax Court · 1952
- A. Finkenberg's Sons, Inc. v. CommissionerUnited States Tax Court · 1951
- Thoms v. CommissionerUnited States Tax Court · 1968
- Mid-State Products Co. v. CommissionerUnited States Tax Court · 1954
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