Legal Opinion

Tilles v. Commissioner

United States Board of Tax Appeals

Decided September 16, 1938No. Docket No. 86505PublishedCited by 13 opinions

In 1932 the petitioner contributed $200 to a fund, to which there were other contributors, to provide a musical education for a poor young girl who had a promising voice. Held, that the amount is not a legal deduction from gross income under section 23(n) of the Revenue Act of 1932.

1Opinion of the Court

OPINION.

Smith:

This proceeding involves deficiencies in petitioner’s income tax for the years 1931 and 1932 in the respective amounts of $3,406.53 and $2,983.99. Petitioner alleges that respondent erred:(1) In disallowing the deduction of losses of $24,305 in 1931 and $29,108.50 in 1932 upon the sale of certain shares of stock in those years.

*546(2) In increasing gross income for each of the years 1931 and 1932 by the amount of $1,800 representing dividends paid in those years on shares of stock which petitioner had pledged as security for payments to his divorced wife.(3) In disallowing the…

2Cases cited5 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Douglas v. WillcutsSupreme Court of the United States · 1935
  3. Perin Ex Rel. Perin v. CareySupreme Court of the United States · 1861
  4. Helvering v. CoxeySupreme Court of the United States · 1936
  5. Kain v. GibboneySupreme Court of the United States · 1879

3Cited by13 opinions

  1. Peace v. CommissionerUnited States Tax Court · 1964
  2. United States v. Joseph E. FlynnCourt of Appeals for the First Circuit · 1973
  3. Davies v. CommissionerUnited States Tax Court · 1963
  4. Mayo v. CommissionerUnited States Tax Court · 1971
  5. Crellin v. CommissionerUnited States Board of Tax Appeals · 1942

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