Legal Opinion

Six v. United States

District Court, S.D. New York

Decided February 8, 1971No. 66 Civ. 2336PublishedCited by 3 opinions

1Opinion of the Court

CANNELLA, District Judge.

This is an action for a refund of federal income taxes paid by the plaintiff Ethel Merman as a result of the disallowance by the Internal Revenue Service [hereinafter “IRS”] of certain hotel and transportation costs as a “traveling expense” within the meaning of 26 U.S.C. § 162(a) (2).

The facts in this case are virtually undisputed. Miss Merman is a well-known entertainer who was born, raised and educated in New York. She has been in “show business” since 1930, performing mainly in the theatre on Broadway. In March, 1953, she married Robert F. Six, the President of…

2Cases cited8 opinions

  1. Commissioner v. FlowersSupreme Court of the United States · 1946
  2. Peurifoy v. CommissionerSupreme Court of the United States · 1958
  3. Commissioner v. StidgerSupreme Court of the United States · 1967
  4. Carragan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
  5. Coerver v. CommissionerUnited States Tax Court · 1961

3 more not listed; retrieve them via the Exa API.

3Cited by3 opinions

  1. Robert F. Six and Ethel Merman Six, Plaintifffs-Appellants v. United StatesCourt of Appeals for the Second Circuit · 1971
  2. Beebe v. CommissionerUnited States Tax Court · 1971
  3. Erdman v. CommissionerUnited States Tax Court · 1972

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