Bruce K. Remy and Gail E. Remy - Page 12

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             appears to include non-cash expenditures for fringe                      
             benefits in the form of goods or services."  In support of               
             this assertion, petitioners cite Wright v. Commissioner,                 
             T.C. Memo. 1992-60, in which the Court permitted the                     
             operator of a barter exchange to deduct under section                    
             162(a) the value of "trade units", the medium of exchange                
             for transactions between members of the barter exchange,                 
             that the taxpayer repaid to the exchange to correct                      
             deficits created by other members.  Petitioners also cite                
             Sullivan v. Commissioner, T.C. Memo. 1982-150, in which the              
             Court allowed a service station operator to deduct the cost              
             of beer that he offered to his customers free of charge                  
             while their vehicles were being filled with gasoline or                  
             serviced.  Finally, petitioners cite Newark Morning Ledger               
             Co. v. United States, 507 U.S. 546 (1993), which                         
             petitioners argue establishes "an important conceptual                   
             landmark which, in this instance, would allow a basis for                
             the valuation and favorable tax treatment of legitimate                  
             services provided by a business owner for the benefit of                 
             his customers to engender good will, under the advertising               
             expenses expressly allowable under Reg. section 1.162-1."                
                  Petitioners fail to perceive that section 162 limits                
             the expenses that a cash basis taxpayer can deduct to those              
             which are "paid" during the year.  Petitioners also fail to              






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