Legal Opinion

Coke v. Commissioner

United States Tax Court

Decided September 24, 1951No. Docket No. 25822Published

Certain legal expenses claimed by petitioner as ordinary and necessary nonbusiness expenses deductible under section 23 (a) (2), I. R. C., held, not deductible from gross income but capital expenditures insofar as allocable to recovery of title to property, but, held, deductible from gross income under section 23 (a) (2) insofar as paid or incurred for the production or collection of income.

1Opinion of the Court

Agnes Pyne Coke, Petitioner, v. Commissioner of Internal Revenue, Respondent

Coke v. Commissioner

Docket No. 25822

United States Tax Court

17 T.C. 403; 1951 U.S. Tax Ct. LEXIS 87;

September 24, 1951, Promulgated

Decision will be entered under Rule 50.

Certain legal expenses claimed by petitioner as ordinary and necessary nonbusiness expenses deductible under section 23 (a) (2), I. R. C., held, not deductible from gross income but capital expenditures insofar as allocable to recovery of title to property, but, held, deductible from gross income under section 23 (a) (2) insofar as paid or incurred for…

2Cases cited14 opinions

  1. Murphy Oil Co. v. BurnetSupreme Court of the United States · 1932
  2. Mallinckrodt v. CommissionerUnited States Tax Court · 1943
  3. JONES'ESTATE v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1942
  4. Bowers v. LumpkinCourt of Appeals for the Fourth Circuit · 1944
  5. Murphy Oil Co. v. BurnetCourt of Appeals for the Ninth Circuit · 1932

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