Legal Opinion
Bilzerian v. United States
United States Court of Federal Claims
Decided June 12, 1998No. 91-1076TPublishedCited by 3 opinions
1Opinion of the Court
OPINION
SMITH, Chief Judge.
Paul Bilzerian and his wife, Terri Steffen, filed this suit to recover taxes, penalties, and interest that they claim were erroneously and illegally assessed against them when the Internal Revenue Service (IRS) denied a deduction on their 1985 tax returns. The disputed deduction arises out of a $125,000 payment made in 1985 by Paul Bilzerian (Bilzerian) to Jefferies and Company (Jefferies), a stock broker. Bilzerian claims that this payment qualified as an “ordinary and necessary business expense” and was thus deductible under 26 U.S.C. § 162(a). The government…
2Cases cited21 opinions
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- United States v. Paul A. BilzerianCourt of Appeals for the Second Circuit · 1991
- Emich Motors Corp. v. General Motors Corp.Supreme Court of the United States · 1951
- Commissioner v. TellierSupreme Court of the United States · 1966
- Textile Mills Securities Corp. v. CommissionerSupreme Court of the United States · 1941
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3Cited by3 opinions
- Steffen v. United StatesCourt of Appeals for the Federal Circuit · 2021
- Shell Petroleum, Inc. v. United StatesUnited States Court of Federal Claims · 2001
- Manning v. Comm'rUnited States Tax Court · 2009