Trebilcock v. Commissioner

64 T.C. 852 (1975)

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Trebilcock v. Commissioner

United States Tax Court
64 T.C. 852 (1975)

  • Written by Heather Whittemore, JD

Facts

Lionel Trebilcock (plaintiff), the owner of a wood-products brokerage company called Litco Products (Litco), hired Reverend James Wardrop to minister to his employees. To do so, Wardrop held prayer meetings and counseled Litco employees on personal and business matters. Wardrop had no business experience and gave business advice based on answers he received during prayer. In addition to ministering and counseling, Wardrop performed various business-related tasks for Litco, including running errands, visiting sawmills, and dropping off mail. Trebilcock deducted the amount he paid Wardrop from his income taxes as business expenses. The Commissioner of Internal Revenue (the Commissioner) (defendant) disallowed all of Trebilcock’s deductions related to Wardrop’s employment and reclassified the expenses as personal expenses. Trebilcock petitioned the United States Tax Court for a redetermination.

Rule of Law

Issue

Holding and Reasoning (Wiles, J.)

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Federal Income Tax

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