Rees Blow Pipe Mfg. Co. v. Commissioner
United States Tax Court
In 1954 petitioner transferred a building to Sanfran Company in a three-way agreement among petitioner, Sanfran, and Stauffer Chemical. In 1955 Sanfran filed suit against petitioner for willful or negligent misrepresentation of the building.
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In 1954 petitioner transferred a building to Sanfran Company in a three-way agreement among petitioner, Sanfran, and Stauffer Chemical. In 1955 Sanfran filed suit against petitioner for willful or negligent misrepresentation of the building. The trial court found Sanfran was entitled to a judgment of $ 20,000 against petitioner, which judgment was affirmed in 1959. Petitioner claimed a deduction for the judgment in 1959 and a deduction for legal fees paid in connection with the suit in 1960. Respondent disallowed the deductions in the amounts of $ 17,780.93 and $ 3,712.43, respectively. Held,…
1Opinion of the Court
OPINION
Arundell, Judge:
Respondent determined deficiencies in income tax for the calendar years 1959 and 1960 in the amounts of $7,007.16 and $1,659.99, respectively.
The only issue is whether petitioner is entitled to deduct $17,780.93 in 1959 by reason of a judgment obtained against it which was affirmed in 1959, and also whether petitioner is entitled to deduct $3,712.43 in 1960 by reason of legal fees paid in connection with the suit.
The facts were stipulated and are so found.
Petitioner is a corporation, incorporated under the laws of the State of California in 1911 and since that time has…
2Cases cited7 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- United States v. LewisSupreme Court of the United States · 1951
2 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Bresler v. CommissionerUnited States Tax Court · 1975
- Horne v. CommissionerUnited States Tax Court · 1972
- Mitchell v. CommissionerUnited States Tax Court · 1969
- Arthur H. Du Grenier, Inc. v. CommissionerUnited States Tax Court · 1972
- Rees Blow Pipe Manufacturing Company v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Rees Blow Pipe Manufacturing CompanyCourt of Appeals for the Ninth Circuit · 1965
18 more not listed; retrieve them via the Exa API.