Legal Opinion

Potter Electric Signal and Manufacturing Company, a Corporation v. Commissioner of Internal Revenue

Court of Appeals for the Eighth Circuit

Decided January 23, 1961No. 16579PublishedCited by 24 opinions

1Opinion of the Court

VOGEL, Circuit Judge.

Petitioner seeks review of a decision of the Tax Court redetermining deficiencies in its income taxes for the years 1950, 1951 and 1952. The court disallowed part of the sums deducted as rent, paid to a trustee landlord, on the grounds that such rent was not required to be paid within the meaning of § 23(a) (1) (A) of the Internal Revenue Code of 1939, 26 U.S.C.A., which provides:

“§ 23. Deductions from gross income. In computing net income there shall be allowed as deductions: (As amended by Sec. 121(a), Revenue Act of 1942, c. 619, 56 Stat. 798, 819.)
“(a) Expenses.
“(1)…

2Cases cited17 opinions

  1. Place v. CommissionerUnited States Tax Court · 1951
  2. Limericks, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1948
  3. Skemp v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1948
  4. Brown v. Commissioner of Internal Revenue (Two Cases)Court of Appeals for the Third Circuit · 1950
  5. Limericks, Inc. v. CommissionerUnited States Tax Court · 1946

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

3Cited by24 opinions

  1. Levenson & Klein, Inc. v. CommissionerUnited States Tax Court · 1977
  2. Sparks Nugget, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1972
  3. Feldman v. CommissionerUnited States Tax Court · 1985
  4. Jack's Cookie Company v. The United States of AmericaCourt of Appeals for the Fourth Circuit · 1979
  5. Tillotson v. McCroryDistrict Court, D. Nebraska · 1962

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

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