Thompson v. Commissioner
United States Board of Tax Appeals
1. Expenditures for surveys, geological opinions, settlement of suits involving title to lands, abstracts of title and legal opinions upon titles are not deductible as ordinary and necessary expenses but are capital expenditures to be added to cost of the property and considered in computing gain or loss on the sale thereof. 2. Testimony that certain sums were paid for labor, and for drilling oil wells held insufficient to establish that such payments were deductible as…
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1. Expenditures for surveys, geological opinions, settlement of suits involving title to lands, abstracts of title and legal opinions upon titles are not deductible as ordinary and necessary expenses but are capital expenditures to be added to cost of the property and considered in computing gain or loss on the sale thereof. 2. Testimony that certain sums were paid for labor, and for drilling oil wells held insufficient to establish that such payments were deductible as ordinary and necessary expenses of a business. 3. An agreement was made to assign an interest in a certain contract for cash…
1Opinion of the Court
*1344OPINION.
Phillips :
This proceeding is presented to us on depositions, taken by counsel other than the attorney of record, which include as exhibits several hundred canceled checks and check book stubs containing wholly inadequate memoranda of the purposes for which the checks were drawn, and some testimony as to the general purposes for which such checks were drawn. On the basis of this evidence we are asked to restate petitioner’s entire income and *1345deductions for 1919. The deficiencies in the evidence have to do mainly with deductions claimed as expenses of carrying on a business. The…
2Cited by23 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Lanrao, Inc. v. United StatesCourt of Appeals for the Sixth Circuit · 1970
- Hoffman v. CommissionerUnited States Tax Court · 1966
- Larsen v. CommissionerUnited States Tax Court · 1976
- Commonwealth Title Company v. RothensiesDistrict Court, E.D. Pennsylvania · 1954
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