Reed v. Commissioner
United States Tax Court
The petitioners incurred attorneys' fees and related expenses in pursuance of two causes of action. In the first they sought to have a constructive trust, preliminary to a reconveyance, imposed on a certain partnership interest. In the second cause of action they sought rescission of a partnership agreement which imposed certain restrictions on the free transfer of a partnership interest belonging to the petitioner wife.
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The petitioners incurred attorneys' fees and related expenses in pursuance of two causes of action. In the first they sought to have a constructive trust, preliminary to a reconveyance, imposed on a certain partnership interest. In the second cause of action they sought rescission of a partnership agreement which imposed certain restrictions on the free transfer of a partnership interest belonging to the petitioner wife. Held, petitioners are not entitled to deduct their legal fees under either sec. 162(a) or sec. 212, I.R.C. 1954. The expenditures were incurred in acquiring or in defending…
1Opinion of the Court
Stass Reed and Martha Reed, Petitioners v. Commissioner of Internal Revenue, Respondent
Reed v. Commissioner
Docket Nos. 5485-67, 406-68
United States Tax Court
55 T.C. 32; 1970 U.S. Tax Ct. LEXIS 55;
October 8, 1970, Filed
Decisions will be entered for the respondent.
The petitioners incurred attorneys' fees and related expenses in pursuance of two causes of action. In the first they sought to have a constructive trust, preliminary to a reconveyance, imposed on a certain partnership interest. In the second cause of action they sought rescission of a partnership agreement which imposed certain…
2Cases cited24 opinions
- United States v. GilmoreSupreme Court of the United States · 1963
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Lykes v. United StatesSupreme Court of the United States · 1952
- Harrison E. Spangler and Myrtle B. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
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