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Jenkins v. Commissioner
In ''Jenkins v. Commissioner'', T.C. Memo 1983-667 (U.S. Tax Court Memos 1983), the U.S. Tax Court held that the payments Conway Twitty, a legendary country singer, made to investors in a defunct restaurant business known as “Twitty Burger, Inc.” were deductible under § 162 as ordinary and necessary business expenses 〔''Internal Revenue Code'' § 162.〕 of petitioner's business as a country music performer.
==Facts==
The petitioner, Harold L. Jenkins, was a well-known country music singer who was commonly known by his stage name of “Conway Twitty”. Conway had been a musical performer since the 1950s, but it was not until the late 1960s that Conway became well-established in the country music industry.〔''Jenkins v. Commissioner'', T.C. Memo 1983-667 (U.S. Tax Court Memos 1983) at 4.〕 By mid-1970, Conway Twitty had 43 Number 1 hit records.〔
In 1968, Twitty Burger, Inc. was formed by Conway, along with approximately 75 friends and business associates who invested money in Twitty Burger for the operation of Twitty Burger Fast Food Restaurants.〔''Jenkins v. Commissioner'', T.C. Memo 1983-667 (U.S. Tax Court Memos 1983) at 6.〕 Late in 1970, Twitty Burger began to encounter financial difficulties and nearly every Twitty Burger restaurant was closed by 1971.〔''Jenkins v. Commissioner'', T.C. Memo 1983-667 (U.S. Tax Court Memos 1983) at 9.〕 Although he had no assets with which to pay the debentures, Conway decided to repay the investors the amount of their investments with future earnings.〔 On his 1973 and 1974 Federal income tax returns, Conway deducted these total amounts, $92,892.46 and $3,600, respectively, as ordinary and necessary business expenses under § 162.〔''Jenkins v. Commissioner'', T.C. Memo 1983-667 (U.S. Tax Court Memos 1983) at 11.〕
抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』
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