Just a whimsical piece. I’d been talking about tax law all day long, so that was on my brain. My husband has often been told he bears a striking resemblance to Conway Twitty, back when Conway was alive. He (my husband, obviously not Conway) mentioned it a few minutes ago. So, that slammed Conway Twitty and tax law together in my brain, and made me remember a famous decision I learned in law school.
Conway got the bright idea to create a burger franchise called Twitty Burgers. Short story, it went bust, the investors all lost their money, but Conway repaid all of them, in full. Then he claimed those payments as a deductible business expense on his taxes. The IRS strongly disagreed. The case went to court. The judge who ruled in his favor also shared an “Ode to Conway Twitty” in his published decision. I thought you would enjoy it. Of course, the judge needed to stick to his day job and not go into song writing, but it is nice piece of levity for a usually boring subject.
Twitty Burger went belly up
But Conway remained true.
He repaid his investors, one and all.
It was the moral thing to do.
His fans would not have liked it,
It could have hurt his fame,
Had any investors sued him
Like Merle Haggard or Sonny James.
When it was time to file taxes
Conway thought what he would do
Was deduct those payments as a business expense
Under section one-sixty-two.
In order to allow these deductions
Goes the argument of the Commissioner.
The payments must be ordinary and necessary
To a business of the petitioner.
Had Conway not repaid the investors
His career would have been under cloud,
Under the unique facts of this case Held:
The deductions are allowed.