Legal Opinion

Fred W. Amend Co. v. Commissioner

United States Tax Court

Decided November 19, 1970No. Docket No. 5385-67PublishedCited by 23 opinions

Held, amounts expended for the retention of a Christian Science practitioner whose services, during the years in issue, were availed of solely by petitioner's treasurer-board chairman, were not properly deductible by petitioner as an ordinary and necessary expense of its business.

1Opinion of the Court

Irwin, Judge:

Respondent determined deficiencies in petitioner’s income tax for fiscal years 1964 and 1965 in the amounts of $2,768 and $2,998, respectively. The only question presented is whether amounts paid to a Christian Science practitioner and taken as business expenses for “professional services” on petitioner’s income tax returns are deductible under section 162 of the Code.1

FINDINGS OF FACT

Some of the facts have been stipulated by the parties. The stipulation of facts, together with the exhibits attached thereto, are incorporated herein by this reference.

The Fred W. Amend Co.…

2Cases cited25 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Kroll v. CommissionerUnited States Tax Court · 1968
  3. Anderson v. HelveringSupreme Court of the United States · 1940
  4. Challenge Mfg. Co. v. CommissionerUnited States Tax Court · 1962
  5. Gene O. Clark and Faye Clark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959

20 more not listed; retrieve them via the Exa API.

3Cited by23 opinions

  1. Moss v. CommissionerUnited States Tax Court · 1983
  2. Rafter v. CommissionerUnited States Tax Court · 1973
  3. Fred W. Amend Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1971
  4. Pollei v. CommissionerUnited States Tax Court · 1990
  5. Pollei v. CommissionerUnited States Tax Court · 1986

18 more not listed; retrieve them via the Exa API.

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