Legal Opinion

Wolfers v. Commissioner

United States Tax Court

Decided March 21, 1978No. Docket Nos. 6772-75, 6773-75PublishedCited by 18 opinions

Petitioners' subchapter S corporation was required to vacate its business premises to make room for the Federal Reserve Bank of Boston.

Read the full summary

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

  1. Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
  2. Brown Shoe Co. v. CommissionerSupreme Court of the United States · 1950
  3. United States v. Chicago, Burlington & Quincy RailroadSupreme Court of the United States · 1973
  4. Hearn v. CommissionerUnited States Tax Court · 1961
  5. 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

  1. Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
  2. Manocchio v. CommissionerUnited States Tax Court · 1982
  3. John Manocchio v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
  4. Zuanich v. CommissionerUnited States Tax Court · 1981
  5. Halliburton Co. v. CommissionerUnited States Tax Court · 1993

13 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API