Legal Opinion

Brown v. Commissioner

United States Tax Court

Decided October 28, 1952No. Docket Nos. 21343, 23426, 21344, 23425Published

1. Held: Legal fees and expenses incurred in settlement of a claim affecting the title to certain property were capital expenditures and not deductible under the provisions of section 23 (a) (2), I. R. C. 2. Held: The period of administration of an estate had terminated in the year the ordinary administrative duties were completed.

1Opinion of the Court

E. W. Brown, Jr., Petitioner, v. Commissioner of Internal Revenue, Respondent. Gladys Slade Brown, Petitioner, v. Commissioner of Internal Revenue, Respondent

Brown v. Commissioner

Docket Nos. 21343, 23426, 21344, 23425

United States Tax Court

19 T.C. 87; 1952 U.S. Tax Ct. LEXIS 62;

October 28, 1952, Promulgated

Decisions will be entered under Rule 50.

1. Held: Legal fees and expenses incurred in settlement of a claim affecting the title to certain property were capital expenditures and not deductible under the provisions of section 23 (a) (2), I. R. C.

2. Held: The period of administration of an…

2Cases cited8 opinions

  1. Beck v. CommissionerUnited States Tax Court · 1950
  2. Coughlin v. CommissionerUnited States Tax Court · 1944
  3. Chick v. CommissionerUnited States Tax Court · 1946
  4. Chick v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
  5. Stewart v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1952

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