Clark v. Commissioner
United States Tax Court
1. Where petitioner's decedent served as executor and trustee for a period of over five years and received one commission for both services at completion thereof, held, tax on such compensation is limited by section 220 of the Revenue Act of 1939. 2. Legal expenses paid in opposing claim of alleged mismanagement as trustee not deductible under I. R. C., section 23 (a) (2), as amended by section 121 of the Revenue Act of 1942.
1Opinion of the Court
OPINION.
Van Fossan, Judge:
The respondent determined a deficiency in petitioner’s income tax for the year of 1939 in the amount of $2,567.72, consequent on the disallowance, inter alia, of two deductions claimed by petitioner: (1) salaries, fees, etc., $16,250; and (2) attorney’s fees, $1,250. With respect to these items respondent stated in the statement attached to the notice of deficiency as follows:
The item of $1,250.00 paid by the Estate of Frederick Winslow Taylor to an attorney for services rendered to decedent, Edward W. Clark, 3rd, has been added to gross income of said decedent for…
2Cited by20 opinions
- Bartholomew v. CommissionerUnited States Tax Court · 1944
- Josephs v. CommissionerUnited States Tax Court · 1947
- Ingalls v. PattersonDistrict Court, N.D. Alabama · 1958
- Slough v. CommissionerUnited States Tax Court · 1944
- Commissioner of Internal Revenue v. JosephsCourt of Appeals for the Eighth Circuit · 1948
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