T.C. Memo. 2001-18
UNITED STATES TAX COURT
RONALD AND SUE M. LESCHKE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4301-99. Filed January 26, 2001.
R determined that Ps were liable for income tax
deficiencies based on the disallowance of amounts
claimed as business expense deductions by an S
corporation wholly owned by P husband.
Held: Amounts used to purchase gift certificates
for corporate customers are deductible only to the
extent of the $25 limitation set forth in sec. 274(b),
I.R.C.
Held, further, sums paid for gift nut baskets
given to employees are fully deductible pursuant to the
language of secs. 102(c) and 274(b), I.R.C.
Held, further, $100 bills given to employees as
Christmas bonuses are fully deductible as compensation.
Richard A. Frederick, for petitioners.
Christa A. Gruber and Mark J. Miller, for respondent.
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