Legal Opinion

Marcus v. Commissioner

United States Tax Court

Decided August 4, 1964No. Docket Nos. 90590, 3069-62Unpublished

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…

Read the full summary

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

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. United States v. GilmoreSupreme Court of the United States · 1963
  3. Whipple v. CommissionerSupreme Court of the United States · 1963
  4. Helvering v. American Dental Co.Supreme Court of the United States · 1943
  5. Kieselbach v. CommissionerSupreme Court of the United States · 1943

22 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API