Bishop v. Commissioner
United States Tax Court
The minority stockholder of a corporation, holding one-third interest, claimed that the holders of the other two-thirds interest who were partners in two other businesses were conducting their partnership businesses in a manner detrimental to the corporation.
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The minority stockholder of a corporation, holding one-third interest, claimed that the holders of the other two-thirds interest who were partners in two other businesses were conducting their partnership businesses in a manner detrimental to the corporation. Held, the fees of attorneys employed to advise the corporation, and who rendered services culminating in an agreement settling the rival claims were properly deductible by the corporation as ordinary and necessary business expense. Held, further, turning over the partnership income to the corporation in the year it was received,…
1Opinion of the Court
OPINION.
Mulroney, Judge:
This consolidated proceeding arises in connection with five petitioners contesting the determination by the Commissioner of deficiencies in income tax, as follows:
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The petitioner, Pendleton Woolen Mills, was, in the years 1946 and 1947, an Oregon corporation with its principal place of business in Portland, Oregon. Its returns for the taxable years 1946 and 1947 were filed with the collector of internal revenue at Portland, Oregon. C. M. Bishop, Robert C. Bishop, and Charles Kay Bishop are individuals. The returns for C. M. Bishop, as an individual and as…
2Cases cited11 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- United States v. MerrillCourt of Appeals for the Ninth Circuit · 1954
- State Ex Rel. Weede v. BechtelSupreme Court of Iowa · 1952
- Crellin's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1953
- May v. Midwest Refining Co.Court of Appeals for the First Circuit · 1941
6 more not listed; retrieve them via the Exa API.
3Cited by34 opinions
- Newark Morning Ledger Company, a Corporation of the State of New Jersey v. The United States of AmericaCourt of Appeals for the Third Circuit · 1976
- Howard B. Quinn and Charlotte J. Quinn v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1975
- Gaddy v. CommissionerUnited States Tax Court · 1962
- Buff v. CommissionerUnited States Tax Court · 1972
- Larchfield Corporation v. United StatesCourt of Appeals for the Second Circuit · 1966
29 more not listed; retrieve them via the Exa API.