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Snow v. Commissioner, 416 U.S. 500 (1974)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Snow v. Commissioner, 416 U.S. 500 (1974)
Snow v. Commissioner of Internal Revenue No. 73-641 Argued April 16, 1974 Decided May 13, 1974 416 U.S. 500
CERTIORARI TO THE UNITE:D STATES COURT OF
APPEALS FOR THE SIXTH CIRCUIT
Syllabus
Petitioner Edwin A. Snow, who had advanced part of the capital in a partnership formed in 1966 to develop a special purpose incinerator and had become a limited partner, was disallowed a deduction under § 174(a)(1) of the Internal Revenue Code of 1954, on his individual income tax return for that year for his pro rata share of the partnership’s operating loss. Though there were no sales in 1966, expectations were high and the inventor-partner was giving about a third of his time to the project, an outside engineering firm doing the shopwork. The Tax Court and the Court of Appeals both upheld disallowance of the deduction, which § 174(a)(1) provides for
experimental expenditures which are paid or incurred by [the taxpayer] during the taxable year in connection with his trade or business as expenses which are not chargeable to capital account.
Held: It was error to disallow the deduction, which was "in connection with" petitioner’s trade or business, and the disallowance was contrary to the broad legislative objective of the Congress when it enacted § 174 to provide an economic incentive, especially for small and growing businesses, to engage in the search for new products and new inventions. Pp. 502-504.
482 F.2d 1029, reversed.
DOUGLAS, J., delivered the opinion of the Court in which all Members joined except STEWART, J., who took no part in the consideration or decision of the case.
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Chicago: U.S. Supreme Court, "Syllabus," Snow v. Commissioner, 416 U.S. 500 (1974) in 416 U.S. 500 416 U.S. 501. Original Sources, accessed November 24, 2024, http://originalsources.com/Document.aspx?DocID=NU3ZPK1KGXQ5YRK.
MLA: U.S. Supreme Court. "Syllabus." Snow v. Commissioner, 416 U.S. 500 (1974), in 416 U.S. 500, page 416 U.S. 501. Original Sources. 24 Nov. 2024. http://originalsources.com/Document.aspx?DocID=NU3ZPK1KGXQ5YRK.
Harvard: U.S. Supreme Court, 'Syllabus' in Snow v. Commissioner, 416 U.S. 500 (1974). cited in 1974, 416 U.S. 500, pp.416 U.S. 501. Original Sources, retrieved 24 November 2024, from http://originalsources.com/Document.aspx?DocID=NU3ZPK1KGXQ5YRK.
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