Legal Opinion

Dorzback v. Collison

District Court, D. Delaware

Decided October 25, 1950No. Civ. No. 1138PublishedCited by 6 opinions

1Opinion of the Court

LEAHY, Chief Judge.

Plaintiff sought recovery of $20,159.46 'of income taxes and interest paid to the Delaware Collector for 1943-44-45. The case was tried by jury. Two issues were presented: (1) Were amounts paid by taxpayer to wife (representing 25% of the net income of his clothing store business) in lieu of interest on a debt he owed her deductible from gross income; and (2) were amounts paid to son reasonable compensation for services actually rendered by son in the business. The jury decided in plaintiff’s favor on both issues.

At trial, I directed the jury to bring in a verdict that…

2Cases cited5 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Commissioner of Internal Revenue v. ParkCourt of Appeals for the Third Circuit · 1940
  3. Kena, Inc. v. CommissionerUnited States Board of Tax Appeals · 1941
  4. Specialty Engineering Co. v. CommissionerUnited States Tax Court · 1949
  5. Foster v. CommissionerUnited States Board of Tax Appeals · 1941

3Cited by6 opinions

  1. James D. Kennedy, Jr. And Dorothy H. Kennedy, and Cherokee Warehouses, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1982
  2. Titcher v. CommissionerUnited States Tax Court · 1971
  3. Dorzback v. Collison, Collector of Internal RevenueCourt of Appeals for the Third Circuit · 1952
  4. Woodward v. United StatesDistrict Court, N.D. Iowa · 1952
  5. Kaider v. Comm'rUnited States Tax Court · 2011

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