Legal Opinion
First National Bank of Atlanta v. United States
District Court, N.D. Georgia
Decided January 12, 1962No. Civ. A. No. 6788PublishedCited by 2 opinions
1Opinion of the Court
HOOPER, District Judge.
This is an action brought by the Executors of the Estate of Gus T. Dodd, deceased, against the Government for refund of taxes. Plaintiffs contend that a certain fee of $25,000.00 paid by deceased in his lifetime was a deductible item, the Government does not agree. After many motions and hearings in the case it finally resolved itself down into a determination of these two questions.
1— Did the fee represent part of “the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business,” within the purview of § 23(a) (1) (A)…
2Cases cited9 opinions
- Kornhauser v. United StatesSupreme Court of the United States · 1928
- Ward v. CommissionerUnited States Tax Court · 1953
- Edward Folker v. James W. Johnson, Individually and as a Former Collector of Internal RevenueCourt of Appeals for the Second Circuit · 1956
- Commissioner of Int. Rev. v. People's-Pittsburgh Trust Co.Court of Appeals for the Third Circuit · 1932
- Flood v. United StatesCourt of Appeals for the First Circuit · 1943
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3Cited by2 opinions
- Meersman v. CommissionerUnited States Tax Court · 1993
- Croft v. United StatesDistrict Court, N.D. Georgia · 1964