Legal Opinion

Long v. Commissioner

United States Tax Court

Decided May 29, 1959No. Docket No. 64164PublishedCited by 17 opinions

Held, for failure of proof, that petitioners are not entitled to deduct as ordinary and necessary business expenses either campaign expenses incurred in running for election to the governing board of a business-social club or more than two-thirds of membership dues paid to certain clubs.

1Opinion of the Court

BRUCE, Judge:

This proceeding involves a deficiency in income tax for the year 1953 in the amount of $988.86.

The issues for decision are (1) whether amounts expended by a lawyer in campaigning for election to the governing board of a business-social club constitute ordinary and necessary expenses of his law practice, and, if so, whether such expenditures are capital in nature, and (2) whether respondent erred in disallowing as ordinary and necessary business expense deductions one-third of certain club membership dues paid by said lawyer.

FINDINGS OF FACT.

Some of the facts were stipulated, are…

2Cases cited4 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. McDonald v. CommissionerSupreme Court of the United States · 1944
  3. Sutter v. CommissionerUnited States Tax Court · 1953
  4. Boehm v. CommissionerUnited States Board of Tax Appeals · 1937

3Cited by17 opinions

  1. Henry v. CommissionerUnited States Tax Court · 1961
  2. Reed v. CommissionerUnited States Tax Court · 1960
  3. Sholund v. CommissionerUnited States Tax Court · 1968
  4. Maness v. CommissionerUnited States Tax Court · 1970
  5. Finney v. CommissionerUnited States Tax Court · 1980

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