Dyer v. Commissioner
United States Tax Court
1. Held, collateral estoppel does not apply in this proceeding against petitioners due to our decision in J. Raymond Dyer, 36 T.C. 456 (1961). The parties in this proceeding are the same as in 36 T.C. 456, supra, but the facts are not the same. 2. Held, certain expenditures made by the petitioners in 1958 were deductible under section 162, I.R.C. 1954, as conceded by respondent at the hearing and in his brief; held, further, certain other expenditures made by the petitioners…
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1. Held, collateral estoppel does not apply in this proceeding against petitioners due to our decision in J. Raymond Dyer, 36 T.C. 456 (1961). The parties in this proceeding are the same as in 36 T.C. 456, supra, but the facts are not the same. 2. Held, certain expenditures made by the petitioners in 1958 were deductible under section 162, I.R.C. 1954, as conceded by respondent at the hearing and in his brief; held, further, certain other expenditures made by the petitioners in 1958 and 1959 were not deductible under either section 162 or section 212 of the 1954 Code.
1Opinion of the Court
J. Raymond Dyer and Jean Russell Dyer v. Commissioner.
Dyer v. Commissioner
Docket No. 4499-62.
United States Tax Court
T.C. Memo 1964-200; 1964 Tax Ct. Memo LEXIS 136; 23 T.C.M. (CCH) 1208; T.C.M. (RIA) 64200;
July 23, 1964
1. Held, collateral estoppel does not apply in this proceeding against petitioners due to our decision in J. Raymond Dyer, 36 T.C. 456 (1961). The parties in this proceeding are the same as in 36 T.C. 456, supra, but the facts are not the same.
2. Held, certain expenditures made by the petitioners in 1958 were deductible under section 162, I.R.C. 1954, as conceded by respondent…
2Cases cited16 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- R. Walter Graham and Dorothy H. Graham v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1964
- J. Raymond Dyer v. Securities and Exchange CommissionCourt of Appeals for the Eighth Circuit · 1961
- Nancy Corinne Dyer and J. Raymond Dyer v. Securities and Exchange Commission, Union Electric Company, Acorporation, Intervenor-RespondentCourt of Appeals for the Eighth Circuit · 1958
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