Legal Opinion
Commissioner of Internal Revenue v. Switlik (Four Cases)
Court of Appeals for the Third Circuit
Decided September 12, 1950No. 10166-10169_1PublishedCited by 19 opinions
1Opinion of the Court
KALODNER, Circuit Judge.
These petitions for review present a novel facet of a problem not unfamiliar in the field of tax law. The question is ■whether payments made by the taxpayers in 1944 in satisfaction of their respective liabilities as transferees are deductable as ordinary losses in that taxable year. The Tax Court, one judge dissenting, concluded that the payments are deductible in full from gross income as ordinary losses under Section 23(e) (2) of the Internal Revenue Code, 26 U.S.C.A. § 23(e)(2). 1 !3 t.C. 121.
There is no controversy as to the basic facts. The taxpayers, in August,…
2Cases cited14 opinions
- Hormel v. HelveringSupreme Court of the United States · 1941
- Phillips v. CommissionerSupreme Court of the United States · 1931
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Dobson v. CommissionerSupreme Court of the United States · 1944
9 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Bernard A. Mitchell and Marjorie Mitchell v. The United StatesUnited States Court of Claims · 1969
- Wofford v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. WoffordCourt of Appeals for the Fifth Circuit · 1953
- Commissioner of Internal Revenue v. Arrowsmith Commissioner of Internal Revenue v. VivianCourt of Appeals for the Second Circuit · 1952
- Duveen Bros., Inc. v. CommissionerUnited States Tax Court · 1951
14 more not listed; retrieve them via the Exa API.