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Respondent determined deficiencies in petitioners' 1990 and
1991 Federal income taxes in the amounts of $2,896 and $1,843,
respectively.
The sole issue for decision is whether petitioners are
entitled to claim deductions for political contributions as
ordinary and necessary business expenses under section 162.
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioners resided in McLoud,
Oklahoma, on the date the petition was filed in this case.
Hereinafter, references to petitioner in the singular are to
James Walker.
Petitioner is an attorney who specializes in lobbying
activities. During 1990 and 1991, he represented business
clients involved in banking, savings and loans, dentistry,
insurance, and the cable and trucking industries. During 1990
and 1991, petitioner traveled to Washington, D.C. to lobby on
behalf of his cable, trucking and savings and loan clients, and
regularly attended Oklahoma legislature meetings as a lobbyist.
Petitioner was reimbursed by his law firm, a professional
corporation, for business expenses including travel, meals, and
entertainment which petitioner incurred in the performance of his
lobbyist activities. The law firm, in turn, was reimbursed for
these expenses by the clients the firm represented.
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