Legal Opinion

Reuter v. Commissioner

United States Tax Court

Decided December 29, 1961No. Docket No. 87400Published

Held, that petitioner is not entitled to deduct for income tax purposes, as an ordinary and necessary expense under either section 162 or section 212 of the 1954 Code, the amounts which he paid as additions to tax under section 6651(a) for the delinquent filing of a Federal excise tax return.

1Opinion of the Court

John Reuter, Jr., Petitioner, v. Commissioner of Internal Revenue, Respondent

Reuter v. Commissioner

Docket No. 87400

United States Tax Court

37 T.C. 599; 1961 U.S. Tax Ct. LEXIS 4;

December 29, 1961, Filed

Decision will be entered for the respondent.

Held, that petitioner is not entitled to deduct for income tax purposes, as an ordinary and necessary expense under either section 162 or section 212 of the 1954 Code, the amounts which he paid as additions to tax under section 6651(a) for the delinquent filing of a Federal excise tax return.

William McRae, Esq., for the petitioner.

Wesley A. Dierberger,…

2Cases cited9 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Higgins v. SmithSupreme Court of the United States · 1940
  3. Commissioner v. HeiningerSupreme Court of the United States · 1943
  4. McDonald v. CommissionerSupreme Court of the United States · 1944
  5. Tank Truck Rentals, Inc. v. CommissionerSupreme Court of the United States · 1958

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