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United Title Insurance Co. v. Commissioner

T.C. Memo. 1988–38 (1988)

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United Title Insurance Co. v. Commissioner

United States Tax Court
T.C. Memo. 1988–38 (1988)

Facts

United Title Insurance Company (United) (plaintiff), a small and relatively new real estate title-insurance company in North Carolina, operated in an intensely competitive industry. Facing significant competitive disadvantages, United focused its marketing efforts on building and maintaining close business relationships with select real estate professionals who could directly refer business to the company. Between 1977 and 1979, United held four out-of-state board meetings and planning conferences. United invited selected real estate attorneys, developers, realtors, and lenders to attend and participate in these events. Spouses and friends also attended some of the trips. On its federal income tax returns for those years, United deducted expenses related to these trips under § 162(a) of the tax code. The commissioner of the Internal Revenue Service (defendant) disallowed the deductions, arguing that the expenses were not “ordinary and necessary” within the meaning of § 162(a) because no other title company in the state engaged in similar practices. United petitioned the tax court for a redetermination.

Rule of Law

Issue

Holding and Reasoning (Parker, J.)

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