Graham v. Commissioner
United States Tax Court
Between March 1947 and March 1954 petitioner acquired a net number of 40,000 shares of stock in the New York Central Railroad Co. Prior to 1955 petitioner was a practicing physician in Baltimore and during 1955 and subsequent years he was the comptroller of Baltimore, which was an elective office. During 1954 petitioner and 14 other individuals and Alleghany Corp. solicited proxies from stockholders of Central in an effort to unseat the then board of directors.
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Between March 1947 and March 1954 petitioner acquired a net number of 40,000 shares of stock in the New York Central Railroad Co. Prior to 1955 petitioner was a practicing physician in Baltimore and during 1955 and subsequent years he was the comptroller of Baltimore, which was an elective office. During 1954 petitioner and 14 other individuals and Alleghany Corp. solicited proxies from stockholders of Central in an effort to unseat the then board of directors. It was agreed by Alleghany and such individuals that the cost of the proxy solicitation would be borne by Alleghany and such 15…
1Opinion of the Court
OPINION
Arundell, Judge:
Respondent determined a deficiency in income tax for the calendar year 1957 in the amount of $8,789.11.
The petition assigns one error as follows:(a) Respondent erroneously disallowed a deduction in the amount of $9,453.00 which he characterized as the “cost of a proxy fight.”
The facts were all stipulated and are so found.
Petitioners are husband and wife, residing in Baltimore, Md. They timely filed a joint Federal income tax return for the calendar year 1957 with the district director of internal revenue in Baltimore, Md., on the cash receipts and disbursements basis.…
2Cases cited22 opinions
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- United States v. PatrickSupreme Court of the United States · 1963
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3Cited by10 opinions
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