Marcus v. Commissioner
United States Tax Court
Held: That petitioner was not engaged in carrying on a business of promoting corporations for the purpose of sales of the stock thereof, and that legal fees and expenses incurred by him in connection with the collection of loans made by him to certain corporations are not deductible as ordinary and necessary business expenses under section 162 of the Internal Revenue Code of 1954. Held, further, that the portion of the legal fees and disbursements paid in connection with…
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Held: That petitioner was not engaged in carrying on a business of promoting corporations for the purpose of sales of the stock thereof, and that legal fees and expenses incurred by him in connection with the collection of loans made by him to certain corporations are not deductible as ordinary and necessary business expenses under section 162 of the Internal Revenue Code of 1954. Held, further, that the portion of the legal fees and disbursements paid in connection with suits which is attributable to claims for recovery of the principal of alleged loans is not deductible under section 212 of…
1Opinion of the Court
Samuel Marcus and Sarah Marcus v. Commissioner.
Marcus v. Commissioner
Docket Nos. 90590, 3069-62.
United States Tax Court
T.C. Memo 1964-206; 1964 Tax Ct. Memo LEXIS 131; 23 T.C.M. (CCH) 1240; T.C.M. (RIA) 64206;
August 4, 1964
Held: That petitioner was not engaged in carrying on a business of promoting corporations for the purpose of sales of the stock thereof, and that legal fees and expenses incurred by him in connection with the collection of loans made by him to certain corporations are not deductible as ordinary and necessary business expenses under section 162 of the Internal Revenue Code…
2Cases cited27 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- United States v. GilmoreSupreme Court of the United States · 1963
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Kieselbach v. CommissionerSupreme Court of the United States · 1943
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