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Primuth v. Commissioner
United States Tax Court
54 T.C. 374 (1970)
Facts
David Primuth (plaintiff), while employed as a corporate executive by Foundry Allied Industries, Inc. (Foundry), paid an employment agency to find him a new job. The agency succeeded in finding him an executive position with a different company, and this position required no new or different qualifications from those for his position with Foundry. Primuth sought to deduct the agency’s fee as a business expense. The commissioner of Internal Revenue (defendant) denied the deduction, deeming the agency fee to be a nondeductible personal expense. Primuth appealed to the United States Tax Court.
Rule of Law
Issue
Holding and Reasoning (Sterrett, J.)
Concurrence (Tannenwald, J.)
Dissent (Tietjens, J.)
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