Legal Opinion

Cloud v. Commissioner

United States Tax Court

Decided December 9, 1991No. Docket Nos. 14973-88, 31425-88, 8297-89PublishedCited by 28 opinions

P, an active member of the Democratic Party, was appointed a deputy registrar of the State Bureau of Motor Vehicles in Butler County, Ohio. Deputy registrars operated the State's license bureaus, which charged customers for processing driver's license applications, vehicle registrations, license plates, and license tabs. Deputy registrars in Ohio were appointed pursuant to annual contracts with the Registrar.

Read the full summary

P, an active member of the Democratic Party, was appointed a deputy registrar of the State Bureau of Motor Vehicles in Butler County, Ohio. Deputy registrars operated the State's license bureaus, which charged customers for processing driver's license applications, vehicle registrations, license plates, and license tabs. Deputy registrars in Ohio were appointed pursuant to annual contracts with the Registrar. In order to obtain the appointment and ensure renewal of his contract in following years, P was required to obtain the recommendation of the Democratic Party. In order to get that…

1Opinion of the Court

RUWE, Judge:

Respondent determined deficiencies and additions to tax follows: in petitioners’ Federal income tax as

Year Deficiency 1983 $ 3,640.88

1984 10,341.56

1985 10,594.00

Year Deficiency

1986 $17,666.90

Additions to tax

Sec. 6653(a)(1)1 $182.04

517.08

Sec. 6653(a)(2) 50 percent of the interest due on $3,640.88 50 percent of the interest due on $10,341.56

Additions to tax

Sec. 6653(a)(1)(A) Sec. 6653(a)(1)(B)

Sec. 6661

$2,585.39

2,649.00

Sec. 6661 $4,417

Following concessions, the issues for decision are: (1) Whether petitioners may deduct amounts paid to a county Democratic Party as business expenses…

2Cases cited25 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Neely v. CommissionerUnited States Tax Court · 1985
  3. Commissioner v. HeiningerSupreme Court of the United States · 1943
  4. Bixby v. CommissionerUnited States Tax Court · 1972
  5. Commissioner v. TellierSupreme Court of the United States · 1966

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

3Cited by28 opinions

  1. Shelton v. CommissionerUnited States Tax Court · 1995
  2. Balyan v. Comm'rUnited States Tax Court · 2017
  3. J.P. Sheahan Assoc., Inc. v. CommissionerUnited States Tax Court · 1992
  4. Doe v. CommissionerUnited States Tax Court · 1993
  5. Oatman v. Comm'rUnited States Tax Court · 2017

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

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API