Legal Opinion
Commissioner of Internal Revenue v. Otto C. Doering, Jr., and Lucy T. Doering
Court of Appeals for the Second Circuit
Decided June 30, 1964No. 182, Docket 28322PublishedCited by 24 opinions
1Opinion of the Court
FRIENDLY, Circuit Judge.
The Commissioner of Internal Revenue invites us to reverse a decision of the full Tax Court, 39 T.C. 647 (1963), permitting the taxpayer to deduct $6,760 of legal fees and related expenses as an ordinary and necessary expense paid or incurred “for the production or collection of income” under § 212(1) of the Inter*740nal Revenue Code of 1954. We must decline the invitation.
The taxpayer, Otto C. Doering, Jr., had long owned stock, ultimately 20%, of Argosy Pictures Corporation, which was engaged in producing motion pictures. In 1950 Argosy contracted with Republic Pictures…
2Cases cited16 opinions
- Burnet v. LoganSupreme Court of the United States · 1931
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Harrison E. Spangler and Myrtle B. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Spreckels v. CommissionerSupreme Court of the United States · 1942
- Commissioner of Internal Revenue v. CarterCourt of Appeals for the Second Circuit · 1948
11 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Fred W. Woodward and Elsie M. Woodward, F. R. Woodward and M. Jeanne Woodward v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1969
- H. H. Helgerson and D. F. Helgerson v. United States of America, Frank C. Powell, Jr., and Doris Dae Powell v. United StatesCourt of Appeals for the Eighth Circuit · 1970
- Viktor Petschek and Mary Petschek v. United StatesCourt of Appeals for the Second Circuit · 1964
- Baier v. Comm'rUnited States Tax Court · 1975
- Estate of Meade v. CommissionerCourt of Appeals for the Fifth Circuit · 1974
19 more not listed; retrieve them via the Exa API.