Legal Opinion

Connelly v. Commissioner

United States Tax Court

Decided April 17, 1946No. Docket Nos. 5153, 6006Published

1. In each of the taxable years the petitioner made a contribution to a county fair association which was required by its lease from the county to hold an agricultural fair each year. The Commonwealth of Pennsylvania appropriated money for the support of the association.

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1. In each of the taxable years the petitioner made a contribution to a county fair association which was required by its lease from the county to hold an agricultural fair each year. The Commonwealth of Pennsylvania appropriated money for the support of the association. Held, that the contributions are legal deductions from gross income under section 23 (o), I. R. C. 2. In 1941 the petitioner paid attorneys' fees in connection with litigation involving a deficiency in income tax for 1934. Held, that the amount is a legal deduction from gross income. Howard E. Cammack, 5. T. C. 467, followed.

1Opinion of the Court

James A. Connelly, Petitioner, v. Commissioner of Internal Revenue, Respondent

Connelly v. Commissioner

Docket Nos. 5153, 6006

United States Tax Court

6 T.C. 744; 1946 U.S. Tax Ct. LEXIS 227;

April 17, 1946, Promulgated

Decisions will be entered under Rule 50.

1. In each of the taxable years the petitioner made a contribution to a county fair association which was required by its lease from the county to hold an agricultural fair each year. The Commonwealth of Pennsylvania appropriated money for the support of the association. Held, that the contributions are legal deductions from gross income under…

2Cases cited4 opinions

  1. Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
  2. Cammack v. CommissionerUnited States Tax Court · 1945
  3. Connelly v. CommissionerUnited States Tax Court · 1946
  4. McKenna v. CommissionerUnited States Tax Court · 1945

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