Estate of Rockefeller v. Commissioner
United States Tax Court
On Aug. 20, 1974, President Ford nominated Nelson A. Rockefeller to serve as Vice President of the United States pursuant to the 25th Amendment to the United States Constitution. In 1975, Mr. Rockefeller paid expenses in the amount of $ 550,159.78 incurred in connection with investigations and congressional hearings on the confirmation of his nomination.
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On Aug. 20, 1974, President Ford nominated Nelson A. Rockefeller to serve as Vice President of the United States pursuant to the 25th Amendment to the United States Constitution. In 1975, Mr. Rockefeller paid expenses in the amount of $ 550,159.78 incurred in connection with investigations and congressional hearings on the confirmation of his nomination. Held, the expenses so incurred and paid by Mr. Rockefeller are not deductible under sec. 162(a) or sec. 162(e), I.R.C. 1954.
1Opinion of the Court
OPINION
Featherston, Judge:
Respondent determined a deficiency in the amount of $44,293 in the Federal income tax of Nelson A. Rockefeller, deceased, and Margaretta F. Rockefeller for 1975. Petitioners in this proceeding allege that the determination was erroneous and claim an overpayment of income tax in the amount of $355,180 for that year. Other issues having been resolved, the only issue for decision is whether the legal fees and other expenses in the stipulated amount of $550,159.78 incurred and paid by Mr. Rockefeller in connection with his confirmation as Vice President of the United…
2Cases cited31 opinions
- Primuth v. CommissionerUnited States Tax Court · 1970
- Cammarano v. United StatesSupreme Court of the United States · 1959
- McDonald v. CommissionerSupreme Court of the United States · 1944
- Frank v. CommissionerUnited States Tax Court · 1953
- Davis v. CommissionerUnited States Tax Court · 1976
26 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Cloud v. CommissionerUnited States Tax Court · 1991
- Lacey v. CommissionerUnited States Tax Court · 1963
- Estate of Rockefeller v. CommissionerCourt of Appeals for the Second Circuit · 1985
- Jones v. CommissionerUnited States Tax Court · 1988
- Gallo v. CommissionerUnited States Tax Court · 1998
8 more not listed; retrieve them via the Exa API.