Legal Opinion

Austin v. Commissioner

United States Tax Court

Decided February 1, 1962No. Docket No. 83870Unpublished

Held, that the petitioners have not carried their burden of proof to show error in the respondent's disallowance of certain expenses and losses claimed as deductions on their returns, and alleged by petitioners to have been incurred and sustained in carrying on a trade or business of "research, experimentation and development."

1Opinion of the Court

Leonard E. Austin and Dorothy Austin v. Commissioner.

Austin v. Commissioner

Docket No. 83870.

United States Tax Court

T.C. Memo 1962-22; 1962 Tax Ct. Memo LEXIS 287; 21 T.C.M. (CCH) 102; T.C.M. (RIA) 62022;

February 1, 1962

Held, that the petitioners have not carried their burden of proof to show error in the respondent's disallowance of certain expenses and losses claimed as deductions on their returns, and alleged by petitioners to have been incurred and sustained in carrying on a trade or business of "research, experimentation and development."

Porter B. Williamson, Esq., 2219 E. Cedar St.,…

2Cases cited3 opinions

  1. Podems v. CommissionerUnited States Tax Court · 1955
  2. Marvin A. Heidt and Beatrice Heidt v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1959
  3. Belden v. CommissionerUnited States Board of Tax Appeals · 1934

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