Legal Opinion

Holeproof Hosiery Co. v. Commissioner

United States Board of Tax Appeals

Decided April 13, 1928No. Docket No. 7535Published

1. Disallowance of a deduction for an alleged loss approved. 2. An amount paid in connection with an increase in the capital stock of the petitioner to the State of Wisconsin in accordance with the law of that State held deductible as a tax under section 234(a)(3) of the Revenue Act of 1921. 3. Attorneys' fees paid in the same connection were not ordinary and necessary expenses within the meaning of section 234(a)(1) of the Revenue Act of 1921. 4. An amount paid as rental on…

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1. Disallowance of a deduction for an alleged loss approved. 2. An amount paid in connection with an increase in the capital stock of the petitioner to the State of Wisconsin in accordance with the law of that State held deductible as a tax under section 234(a)(3) of the Revenue Act of 1921. 3. Attorneys' fees paid in the same connection were not ordinary and necessary expenses within the meaning of section 234(a)(1) of the Revenue Act of 1921. 4. An amount paid as rental on machines in which the petitioner with each payment acquired an equity was not deductible under section 234(a)(1) of the…

1Opinion of the Court

HOLEPROOF HOSIERY CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Holeproof Hosiery Co. v. Commissioner

Docket No. 7535.

United States Board of Tax Appeals

11 B.T.A. 547; 1928 BTA LEXIS 3769;

April 13, 1928, Promulgated

1. Disallowance of a deduction for an alleged loss approved.

2. An amount paid in connection with an increase in the capital stock of the petitioner to the State of Wisconsin in accordance with the law of that State held deductible as a tax under section 234(a)(3) of the Revenue Act of 1921.

3. Attorneys' fees paid in the same connection were not ordinary and…

2Cases cited25 opinions

  1. Gould v. GouldSupreme Court of the United States · 1917
  2. Norwood v. BakerSupreme Court of the United States · 1898
  3. Gundling v. ChicagoSupreme Court of the United States · 1900
  4. Ward v. MarylandSupreme Court of the United States · 1871
  5. United States v. WoodwardSupreme Court of the United States · 1921

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