Rafter v. Commissioner
United States Tax Court
1. During the years in issue, petitioner was engaged in numerous lawsuits, most of which he initiated. Held, petitioner's expenses relating to such litigation are not deductible under either sec. 162(a) or sec. 212(1), I.R.C. 1954. 2. Held, further, petitioner has not established that he paid business expenses in excess of the amount allowed as a deduction for 1966 within the meaning of sec. 162(a), I.R.C. 1954. 3. Petitioner's automobile was seized under a writ of…
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1. During the years in issue, petitioner was engaged in numerous lawsuits, most of which he initiated. Held, petitioner's expenses relating to such litigation are not deductible under either sec. 162(a) or sec. 212(1), I.R.C. 1954. 2. Held, further, petitioner has not established that he paid business expenses in excess of the amount allowed as a deduction for 1966 within the meaning of sec. 162(a), I.R.C. 1954. 3. Petitioner's automobile was seized under a writ of attachment issued pursuant to an action brought against him for nonpayment of rent. While the automobile was in the sheriff's…
1Opinion of the Court
Featherston, Judge:
Respondent has determined deficiencies in petitioner’s Federal income taxes in the following amounts:
Docket No. Year Amount $350. 10 298. 37 721. 40 1, 497. 53 2044-67. 1966 3976-68.
Concessions having been made, the following issues are presented for decision :(1) Whether certain litigation expenses were incurred by petitioner in the carrying on of a trade or business within the meaning of section 162(a)1 or in the production or collection of income within the meaning of section 212 (1);(2) With regard to petitioner’s representation of two clients in 1966, whether he paid…
2Cases cited27 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- United States v. GilmoreSupreme Court of the United States · 1963
- Kornhauser v. United StatesSupreme Court of the United States · 1928
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Woodward v. CommissionerSupreme Court of the United States · 1970
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3Cited by27 opinions
- Johnson v. CommissionerUnited States Tax Court · 1979
- McKay v. CommissionerUnited States Tax Court · 1994
- Lare v. CommissionerUnited States Tax Court · 1974
- Federal Paper Bd. Co. v. CommissionerUnited States Tax Court · 1988
- McAlister v. CommissionerUnited States Tax Court · 1989
22 more not listed; retrieve them via the Exa API.