Merians v. Commissioner
United States Tax Court
Petitioners paid a fee for legal services in connection with the development and implementation of their estate plan. Held, 20 percent of such fee is allocable to tax advice.
1Opinion of the Court
SimpsoN, Judge:
The respondent determined a deficiency of $1,136.32 in the petitioners’ 1967 Federal income tax. The only issue for decision is whether the petitioners have shown what portion of a $2,144 attorney’s fee was allocable to tax advice.
FINDINGS OP FACT
Some of the facts have been stipulated, and those facts are so found.
■ The petitioners, Dr. Sidney Merians and Susan Merians, are husband and wife, who maintained their legal residence in Edison, N.J., at the time the petition was filed in this case. They filed their 1967 joint Federal income tax return with the district director of…
2Cases cited5 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Schultz v. CommissionerUnited States Tax Court · 1968
- George L. Schultz and Margaret F. Schultz v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1970
- Vest v. CommissionerUnited States Tax Court · 1971
- McDonald v. CommissionerUnited States Tax Court · 1969
3Cited by47 opinions
- Zmuda v. CommissionerUnited States Tax Court · 1982
- Luman v. CommissionerUnited States Tax Court · 1982
- Professional Services v. CommissionerUnited States Tax Court · 1982
- Wildman v. CommissionerUnited States Tax Court · 1982
- Tolwinsky v. CommissionerUnited States Tax Court · 1986
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