Tax court order finding deficiencies in the payments of income taxes is affirmed where: 1) payments to partnerships were distributions to the plaintiffs personally, and thus were not deductible as ordinary and necessary business expenses under Internal Revenue Code sec. 162 (a); and 2) the amounts of the life insurance premiums paid by the plaintiffs are not included as gross income under Internal Revenue Code section 61 (a).
Read De Angelis v. Comm’r of Internal Revenue, No. 08-1143
Appellate InformationAppeal from the United States Tax Court. Argued May 29, 2009Decided July 21, 2009
JudgesBefore: LEVAL, POOLER and PARKER, Circuit Judges.Per Curium Opinion
CounselFor Petitioner: Ira B. Stechel, Wormser, Kiely, Galef & Jacobs LLP, New York, NY,
For Respondent: Randolph L. Hutter, United States Department of Justice, Washington, D.C.
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