Legal Opinion
Hochschild v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided May 16, 1947No. 186, Docket 20445PublishedCited by 79 opinions
1Opinion of the Court
CHASE, Circuit Judge.
In his income tax return for the calendar year 1939 the petitioner deducted $4,125 which he had paid in that year as attorney’s fees incurred in the successful defense of a stockholder’s derivative suit brought against him and others in the state court in New York. The Commissioner disallowed the deduction in full. The Tax Court disallowed the deduction in part and this petition was brought to review that decision.
The pertinent facts were not disputed and were found in accordance with a stipulation filed by the parties. They are that the petitioner has been a direclor and…
2Cases cited11 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Kornhauser v. United StatesSupreme Court of the United States · 1928
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Rassenfoss v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1946
6 more not listed; retrieve them via the Exa API.
3Cited by79 opinions
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Primuth v. CommissionerUnited States Tax Court · 1970
- Joseph Lewis v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
- Industrial Aggregate Company, a Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1960
- E. W. Brown, Jr. And Gladys Slade Brown v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1954
74 more not listed; retrieve them via the Exa API.