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Income Tax Keyed to Lind
Surasky v. United States
Facts
Taxpayer purchased 4000 shares of stock of Montgomery Ward in 1954 and 1955 costing $296,870. Taxpayer and other stockholders formed a Committee known as the Wolfson-Montgomery Ward Stockholders Committee in order to advocate changes in the management of Montgomery Ward. Taxpayer paid the committee $17,000 in 1955 for expenses in carrying out its mission. Three of the committee’s nominees were place on the board of nine directors. The Chairman of the Board and the President resigned which was a goal of the committee. Taxpayer received dividends of $30,000 on the stock and after he sold his stock he realized a capital gain of $50,929. Taxpayer was not allowed to deduct the expenditures on the committee as an ordinary and necessary business expense.
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