Wolfers v. Commissioner
United States Tax Court
Petitioners' subchapter S corporation was required to vacate its business premises to make room for the Federal Reserve Bank of Boston.
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Petitioners' subchapter S corporation was required to vacate its business premises to make room for the Federal Reserve Bank of Boston. The Bank paid the corporation $ 763,900 under the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, a sum which more than sufficed to cover all of the corporation's outlay for moving, increased rental payments under a new lease for the duration of the corporation's old lease, new leasehold improvements at a greatly expanded new location, and other costs associated with the move. The Relocation Act provides that no payment…
1Opinion of the Court
Hall, Judge:
Respondent determined the following deficiencies in petitioners’ Federal income tax for 1972:
Henry L. and Helen F. Wolfers .$37,453.80
Nancy A. Mazzoni . 1,473.00
These cases were consolidated for trial, briefing, and opinion. Both cases concern deductions claimed by and on behalf of Henry L. Wolfers, Inc. (HLW), a subchapter S corporation. Other issues having been settled by the parties, the issues remaining are:(1) Whether deductions claimed by HLW for its taxable year ended February 29, 1972, for relocation expenses, professional fees, and excess rent are allowable under section…
2Cases cited7 opinions
- Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
- Brown Shoe Co. v. CommissionerSupreme Court of the United States · 1950
- United States v. Chicago, Burlington & Quincy RailroadSupreme Court of the United States · 1973
- Hearn v. CommissionerUnited States Tax Court · 1961
- Glendinning, McLeish & Co. v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1932
2 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Manocchio v. CommissionerUnited States Tax Court · 1982
- John Manocchio v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
- Zuanich v. CommissionerUnited States Tax Court · 1981
- Halliburton Co. v. CommissionerUnited States Tax Court · 1993
13 more not listed; retrieve them via the Exa API.