Ramos v. Commissioner
United States Tax Court
Expense vs. Capital Expenditure -- Payment by Life Tenant To Settle Litigation Attacking His Title to Life Estate -- Sec. 212(2), I.R.C. 1954. -- A payment by one granted right to trust income for life in settlement of litigation in which his right or title was attacked is not an ordinary and necessary expense and not deductible under section 212(2), I.R.C. 1954.
1Opinion of the Court
Arturo H. P. Ramos and Mary Estelle Ramos, Petitioners, v. Commissioner of Internal Revenue, Respondent
Ramos v. Commissioner
Docket No. 84507
United States Tax Court
38 T.C. 820; 1962 U.S. Tax Ct. LEXIS 83;
September 11, 1962, Filed
Decision will be entered under Rule 50.
Expense vs. Capital Expenditure -- Payment by Life Tenant To Settle Litigation Attacking His Title to Life Estate -- Sec. 212(2), I.R.C. 1954. -- A payment by one granted right to trust income for life in settlement of litigation in which his right or title was attacked is not an ordinary and necessary expense and not deductible…
2Cases cited15 opinions
- Lykes v. United StatesSupreme Court of the United States · 1952
- Louisiana Land & Exploration Co. v. CommissionerUnited States Tax Court · 1946
- Bowers v. LumpkinCourt of Appeals for the Fourth Circuit · 1944
- Louisiana Land & Exp. Co. v. Commissioner of Int. Rev.Court of Appeals for the Fifth Circuit · 1947
- Safety Tube Corp. v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1948
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