Challenge Mfg. Co. v. Commissioner
United States Tax Court
1. Expenses and depreciation on yacht and other boats owned by corporation, in exclusive possession of its sole stockholder, held not deductible by corporation in excess of amounts allowed by the Commissioner. 2. Certain travel and other expenses paid by corporation held personal and not deductible by corporation. 3. Expenditure for certain stereoviewers held capital outlay rather than business expense. 4. Amounts properly disallowed in 1 and 2 held equal to fair value of…
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1. Expenses and depreciation on yacht and other boats owned by corporation, in exclusive possession of its sole stockholder, held not deductible by corporation in excess of amounts allowed by the Commissioner. 2. Certain travel and other expenses paid by corporation held personal and not deductible by corporation. 3. Expenditure for certain stereoviewers held capital outlay rather than business expense. 4. Amounts properly disallowed in 1 and 2 held equal to fair value of benefits received by sole stockholder and taxable to him as dividends.
1Opinion of the Court
OPINION.
Baum, Judge:
1. The Commissioner disallowed deductions in the amounts of $15,613.48 and $12,772.54 for the years 1956 and 1957, respectively, for expenses and depreciation relating to the yacht Gallant Lady V and other boats owned by the corporate petitioner, Challenge Manufacturing Company. The amounts disallowed were one-half of the total amounts claimed in this connection by Challenge on its returns, and the theory of the Commissioner’s determination was that to the extent of the amounts disallowed the vessels were not used in Challenge’s business.
J. Boss Castendyck was the sole…
2Cases cited14 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- American Properties, Inc. v. CommissionerUnited States Tax Court · 1957
- Louis Greenspon v. Commissioner of Internal Revenue, (Three Cases). Anna Greenspon v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1956
- Greenspon v. CommissionerUnited States Tax Court · 1954
- Walet v. CommissionerUnited States Tax Court · 1958
9 more not listed; retrieve them via the Exa API.
3Cited by197 opinions
- Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
- Falsetti v. CommissionerUnited States Tax Court · 1985
- Ashby v. CommissionerUnited States Tax Court · 1968
- Rushing v. CommissionerUnited States Tax Court · 1969
- Riss v. CommissionerUnited States Tax Court · 1971
192 more not listed; retrieve them via the Exa API.