Legal Opinion

Grossman & Sons v. Commissioner

United States Tax Court

Decided April 11, 1967No. Docket Nos. 1717-65, 1718-65Published

Amount paid by taxpayer in settlement of claims made by the United States in a suit against taxpayer brought under 31 U.S.C. secs. 231-233 (False Claims Act), found on the evidence presented to be common law contractual damages as characterized in taxpayer's settlement offer which was accepted by the United States, held to be deductible. Allowance of the deduction would not frustrate a sharply defined public policy of the United States.

1Opinion of the Court

Grossman & Sons, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent; Rose Wiping Cloths, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Grossman & Sons v. Commissioner

Docket Nos. 1717-65, 1718-65

United States Tax Court

48 T.C. 15; 1967 U.S. Tax Ct. LEXIS 121;

April 11, 1967, Filed

Decisions will be entered under Rule 50.

Amount paid by taxpayer in settlement of claims made by the United States in a suit against taxpayer brought under 31 U.S.C. secs. 231-233 (False Claims Act), found on the evidence presented to be common law contractual damages as characterized in…

Also in this document: Dissent · Bruce; Dissent · Dawson.

2Cases cited26 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. United States Ex Rel. Marcus v. HessSupreme Court of the United States · 1943
  3. Commissioner v. HeiningerSupreme Court of the United States · 1943
  4. Commissioner v. TellierSupreme Court of the United States · 1966
  5. Rex Trailer Co. v. United StatesSupreme Court of the United States · 1956

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