Legal Opinion

Mann v. Commissioner

United States Tax Court

Decided June 17, 1965No. Docket No. 2799-62Unpublished

Expenses incurred by the life beneficiary of a trust, held, deductible as to certain attorney and other fees paid, but not deductible as to amounts not sufficiently substantiated nor shown to have been ordinary and necessary for and reasonably and proximately related to the production and collection of income.

1Opinion of the Court

Ila B. Mann v. Commissioner.

Mann v. Commissioner

Docket No. 2799-62.

United States Tax Court

T.C. Memo 1965-161; 1965 Tax Ct. Memo LEXIS 169; 24 T.C.M. (CCH) 855; T.C.M. (RIA) 65161;

June 17, 1965

Expenses incurred by the life beneficiary of a trust, held, deductible as to certain attorney and other fees paid, but not deductible as to amounts not sufficiently substantiated nor shown to have been ordinary and necessary for and reasonably and proximately related to the production and collection of income.

Selig Kaplan, 16 Court St., New York, N. Y., for the petitioner. Eugene Parker and Robert A.…

2Cases cited6 opinions

  1. Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
  2. Turks Head Club v. BroderickCourt of Appeals for the First Circuit · 1948
  3. Tyler v. CommissionerUnited States Tax Court · 1946
  4. Geary v. CommissionerUnited States Tax Court · 1947
  5. Forbes v. CommissionerUnited States Tax Court · 1952

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