Kenfield v. Commissioner
United States Tax Court
T, an engineer employed by X corporation, made payments to Frederick Chusid & Co. to assist him in obtaining a new job as an engineer with increased compensation. As a result of Chusid's assistance T accepted a new job with Y corporation, but, prior to commencing work at the new job, X corporation in order to induce T to remain offered him a promotion with increased compensation.
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T, an engineer employed by X corporation, made payments to Frederick Chusid & Co. to assist him in obtaining a new job as an engineer with increased compensation. As a result of Chusid's assistance T accepted a new job with Y corporation, but, prior to commencing work at the new job, X corporation in order to induce T to remain offered him a promotion with increased compensation. T thereupon decided to remain with X. T's promotion at X was a direct consequence of his acceptance of the new job at Y. Held, T's payments to Chusid are deductible as ordinary and necessary business expenses. Sec.…
1Opinion of the Court
OPINION
Eauai, Judge:
Petitioner made payments totaling $1,781.75 to Chusid as fees and related expenses in order to find new employment as a design engineer. Though he was successful in eliciting a job offer through Chusid’s assistance which he in fact accepted, he decided at the last moment to remain with his old employer, General Electric. The issue is whether petitioner’s payments to Chusid in connection with his search for a new job are deductible under section 162(a), I.E.C. 1954,1 as ordinary and necessary expenses incurred in his trade or business. We hold that these expenses are…
2Cases cited3 opinions
- Primuth v. CommissionerUnited States Tax Court · 1970
- Motto v. CommissionerUnited States Tax Court · 1970
- Carson J. Morris and Muriel F. Morris v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
3Cited by7 opinions
- Schneider v. CommissionerUnited States Tax Court · 1983
- Evans v. CommissionerUnited States Tax Court · 1981
- Horace E. And Edith B. Nichols v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1975
- Horace E. And Edith B. Nichols v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1975
- Kenfield v. CommissionerUnited States Tax Court · 1970
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