Legal Opinion

Estate of Cohn v. Commissioner

United States Tax Court

Decided March 25, 1974No. Docket No. 2299-71Published

Petitioner, Albert Cohn, for many years prior to his demise, and specifically from Jan. 1, 1964, until his death on July 18, 1968, owned and operated National Rubber Footwear Co., as a sole proprietorship. National was a wholesaler of tennis shoes and rubber boots of a "seconds" quality. Prior to his death, petitioner priced the inventories himself; and none of his employees ever saw his computations or the resulting profit-and-loss statements or the balance sheets.

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Petitioner, Albert Cohn, for many years prior to his demise, and specifically from Jan. 1, 1964, until his death on July 18, 1968, owned and operated National Rubber Footwear Co., as a sole proprietorship. National was a wholesaler of tennis shoes and rubber boots of a "seconds" quality. Prior to his death, petitioner priced the inventories himself; and none of his employees ever saw his computations or the resulting profit-and-loss statements or the balance sheets. In preparing National's periodic financial statements, his accountant relied upon petitioner's inventory computations. After…

1Opinion of the Court

Estate of Albert Cohn, Deceased, Adeline G. Cohn, Jane Lee Rodman, and Harold I. Rodman, Executors, and Adeline G. Cohn, Petitioners v. Commissioner of Internal Revenue, Respondent

Estate of Cohn v. Commissioner

Docket No. 2299-71

United States Tax Court

61 T.C. 787; 1974 U.S. Tax Ct. LEXIS 136; 61 T.C. No. 84;

March 25, 1974, Filed

Decision will be entered under Rule 155.

Petitioner, Albert Cohn, for many years prior to his demise, and specifically from Jan. 1, 1964, until his death on July 18, 1968, owned and operated National Rubber Footwear Co., as a sole proprietorship. National was a…

2Cases cited9 opinions

  1. Steel or Bronze Piston Ring Corp. v. CommissionerUnited States Tax Court · 1949
  2. American Pitch Pine Export Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
  3. John Wanamaker v. CommissionerCourt of Appeals for the Third Circuit · 1932
  4. John Wanamaker Philadelphia v. CommissionerUnited States Board of Tax Appeals · 1931
  5. O. A. Steiner Tire Co. v. CommissionerUnited States Board of Tax Appeals · 1928

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