Legal Opinion
Kenneth B. Schley, Jr., and Frederick J. Hart, Executors of the Estate of Ellen R. Schley, Deceased v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided March 17, 1967No. 29992_1PublishedCited by 31 opinions
1Opinion of the Court
HAYS, Circuit Judge:
The executors of the estate of Ellen R. Schley petition for review of a decision of the Tax Court which upheld the Commissioner in denying Mrs. Schley an income tax deduction and assessing a tax deficiency in her income tax payments for the years 1959-61. The Tax Court’s memorandum findings of fact and opinion are not officially reported.
The issue on this petition is whether the taxpayer is entitled to an income tax deduction for losses incurred in the operation of a farm during the years in question. Petitioners claim that this deduction was proper under Sections 162 (a)…
2Cases cited4 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Corliss Lamont and Margaret I. Lamont v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
- James E. Austin and Elizabeth G. Austin v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
3Cited by31 opinions
- Margit Sigray Bessenyey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Johnson v. CommissionerUnited States Tax Court · 1973
- Paul Snyder and Helen J. Snyder v. United StatesCourt of Appeals for the Tenth Circuit · 1982
- Judith S. Feder v. Martin Marietta Corporation and Sperry Rand CorporationCourt of Appeals for the Second Circuit · 1969
- Canizzo v. Farrell Lines, Inc.Court of Appeals for the Second Circuit · 1978
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