Legal Opinion

Murphy Oil Co. v. Commissioner

United States Board of Tax Appeals

Decided March 30, 1929No. Docket No. 14440Published

1. Legal expenses and a payment in compromise of a suit alleging petitioner acquired oil properties by fraudulent means and seeking to recover the properties, together with an accounting for profits obtained from dealings with such properties, were not personal expenses, nor were they deductible as business expenses, for that portion allocable to the defense of the claim against title was a capital expenditure. 2. The claim for an accounting was a distinct claim involving a…

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1. Legal expenses and a payment in compromise of a suit alleging petitioner acquired oil properties by fraudulent means and seeking to recover the properties, together with an accounting for profits obtained from dealings with such properties, were not personal expenses, nor were they deductible as business expenses, for that portion allocable to the defense of the claim against title was a capital expenditure. 2. The claim for an accounting was a distinct claim involving a distinct group of assets and that portion of the expenses and compromise payment allocable to the defense and settlement…

1Opinion of the Court

MURPHY OIL CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Murphy Oil Co. v. Commissioner

Docket No. 14440.

United States Board of Tax Appeals

15 B.T.A. 1195; 1929 BTA LEXIS 2715;

March 30, 1929, Promulgated

1. Legal expenses and a payment in compromise of a suit alleging petitioner acquired oil properties by fraudulent means and seeking to recover the properties, together with an accounting for profits obtained from dealings with such properties, were not personal expenses, nor were they deductible as business expenses, for that portion allocable to the defense of the claim…

2Cases cited10 opinions

  1. Kornhauser v. United StatesSupreme Court of the United States · 1928
  2. Thompson v. CommissionerUnited States Board of Tax Appeals · 1928
  3. Berg v. CommissionerUnited States Board of Tax Appeals · 1927
  4. Nelson Land & Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1926
  5. Hazlett v. CommissionerUnited States Board of Tax Appeals · 1928

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