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 Information
Appeal from the United States Tax Court.
Argued May 29, 2009
Decided July 21, 2009
Judges
Before: LEVAL, POOLER and PARKER, Circuit Judges.
Per Curium Opinion
Counsel
For 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.
