Legal Opinion

United States v. Patrick

Supreme Court of the United States

Decided February 18, 1963No. 22PublishedCited by 80 opinions

1Opinion of the CourtJustice Harlan

This case presents the question, similar to that decided today in No. 21, United States v. Gilmore, ante, p. 39, as to the deductibility of certain legal fees paid by the re spondent to his attorneys and attorneys representing his wife in connection with divorce proceedings instituted by the wife. In a suit for refund contesting the Commissioner’s disallowance of such a deduction claimed in the taxpayer’s 1956 federal income tax return, the United States District Court for the Western District of South Carolina held these expenses to be deductible under § 212 (2) of the Internal Revenue Code…

2Cases cited5 opinions

  1. Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
  2. Magruder v. SuppleeSupreme Court of the United States · 1942
  3. Baer v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1952
  4. Patrick v. United StatesDistrict Court, W.D. South Carolina · 1960
  5. Talbot Patrick and Commercial Bank of Charlotte, Administrator of the Estate of Alethia M. Patrick, Deceased v. United StatesCourt of Appeals for the Fourth Circuit · 1961

3Cited by80 opinions

  1. Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  2. Hicks Co. v. CommissionerUnited States Tax Court · 1971
  3. Spector v. CommissionerUnited States Tax Court · 1979
  4. Wild v. CommissionerUnited States Tax Court · 1964
  5. H. H. Helgerson and D. F. Helgerson v. United States of America, Frank C. Powell, Jr., and Doris Dae Powell v. United StatesCourt of Appeals for the Eighth Circuit · 1970

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