Carson J. Morris and Muriel F. Morris v. Commissioner of Internal Revenue

Petitioners sought relief in the Tax Court from tax liability resulting from alleged deficiencies in their income tax returns for the taxable years 1962 and 1963. The Tax Court found petitioners’ claims that certain expenses were deductible from gross income to be without merit and ordered full payment of the deficiency, which totaled $716.86. This appeal was taken; our jurisdiction rests upon 26 U.S.C. § 7482 . We affirm.

Factual Background

During the years 1962, 1963 and part of 1964, Carson Morris was employed as a vice president by Campbell-Mithun, an advertising firm in Chicago, Illinois. In 1964 he terminated his employment with that company and immediately thereafter, on May 18, 1964, accepted a position with the Cudahy Packing Company in Phoenix, Arizona.

In 1962 petitioner Morris entered into a contract with Frederick Chusid & Company for the purpose of seeking employment in an executive capacity. (C. T. 66) Chusid is a firm of executive recruiters that refers to itself as “management psychologists” and that performs services by assisting its clients in marketing themselves in areas of suggested or desired employment. (C.T. 66) Pursuant to the contract, Chusid…