Lionel F. Trebilcock and Shirley Trebilcock v. Commissioner of Internal Revenue

Sixth Circuit

Lionel F. Trebilcock and Shirley Trebilcock v. Commissioner of Internal Revenue

557 F.2d 1226, 40 A.F.T.R.2d (RIA) 5243, 1977 U.S. App. LEXIS 12760

Court of Appeals for the Sixth Circuit·Decided June 23, 1977·No. 76-1387·Published·Cited by 2 cases

Opinion

ORDER

This is an appeal from a decision of the Tax Court which is reported at 64 T.C. 852 (1975). The taxpayer, Lionel F. Trebilcock, claimed a business deduction for compensation paid to an ordained minister who was available for spiritual counseling to the taxpayer and the other four employees of the business which he operated as a sole proprietorship. The question before the Tax Court and before this court is whether the expenditures for compensation to the minister were “ordinary and necessary” within the meaning of Section 162(a) of the Internal Revenue Code of 1954. The Tax Court held that such expenditures above the amount of $1,000 per year were not ordinary and necessary business expenses, and we agree.

The decision of the Tax Court is affirmed.

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ORDER

This is an appeal from a decision of the Tax Court which is reported at 64 T.C. 852 (1975). The taxpayer, Lionel F. Trebilcock, claimed a business deduction for compensation paid to an ordained minister who was available for spiritual counseling to the taxpayer and the other four employees of the business which he operated as a sole proprietorship. The question before the Tax Court and before this court is whether the expenditures for compensation to the minister were “ordinary and necessary” within the meaning of Section 162(a) of the Internal Revenue Code of 1954. The Tax Court held that such expenditures above the amount of $1,000 per year were not ordinary and necessary business expenses, and we agree.

The decision of the Tax Court is affirmed.

Lionel F. Trebilcock and Shirley Trebilcock v. Commissioner of Internal Revenue, 557 F.2d 1226, 40 A.F.T.R.2d (RIA) 5243, 1977 U.S. App. LEXIS 12760 (6th Cir. 1977).

Pincite

557 F.2d 1226 (Lionel F. Trebilcock and Shirley Trebilcock v. Commissioner of Internal Revenue) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Opinion

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