Christensen v. Commissioner
United States Tax Court
Deduction -- Ordinary and Necessary Expense -- Section 23 (a) (1) (A). -- Amounts spent by a field manager to build up business and increase his compensation, though spent for the entertainment of salesmen under his supervision, were ordinary and necessary expenses of his business as field manager.
1Opinion of the Court
OPINION.
Murdock, Judge:
The petitioner does not know exactly how much he spent on the salesmen under him and on their wives and children, but he testified that he did spend his own funds for that purpose and he gave as his best estimate of the total, $50 a month or $600 a year for 1947. If he had kept some record, he might have been able to prove the exact amount which he spent. It is not clear whether or not he included in the estimate the amount which he spent for his own entertainment and which might not properly be regarded as an expense of his business as field manager. Some of the…
2Cases cited1 opinion
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
3Cited by29 opinions
- Primuth v. CommissionerUnited States Tax Court · 1970
- Walliser v. CommissionerUnited States Tax Court · 1979
- Marvin A. Heidt and Beatrice Heidt v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1959
- Bodzin v. CommissionerUnited States Tax Court · 1973
- Kurkjian v. CommissionerUnited States Tax Court · 1976
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