Bussabarger v. Commissioner
United States Tax Court
1. Held, on the facts presented, that payments of salary and other benefits to or on behalf of petitioner's former medical secretary during an extended period of illness were for personal reasons and are not deductible as ordinary and necessary business expenses under sec. 162(a) of the Internal Revenue Code of 1954. 2. Held, further, that petitioners have not established that they are entitled to deductions, in excess of the amounts allowed by respondent, for the expenses…
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1. Held, on the facts presented, that payments of salary and other benefits to or on behalf of petitioner's former medical secretary during an extended period of illness were for personal reasons and are not deductible as ordinary and necessary business expenses under sec. 162(a) of the Internal Revenue Code of 1954. 2. Held, further, that petitioners have not established that they are entitled to deductions, in excess of the amounts allowed by respondent, for the expenses of Christmas parties and fishing trips, automobile operating and depreciation expenses, expenses relating to the…
1Opinion of the Court
OPINION
The principal issue presented is whether salary, FICA, and pension fund payments made by the petitioner, Dr. Eobert A. Bussabarger, in 1963 and 1964 to or on behalf of his former medical secretary, Janice Edwards, are deductible as ordinary and necessary business expenses.
Section 162(a) of the Internal Bevenue Code of 19542 provides in pertinent part:
SEC. 162. TRADE OR BUSINESS EXPENSES.(a) lx General. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including—(1) a reasonable…
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