Livingood v. Commissioner
United States Board of Tax Appeals
Held that attorney fees incurred in connection with a proceeding in court to partition certain properties and in other matters growing therefrom were not deductible as ordinary and necessary expenses paid or incurred in carrying on a trade or business.
1Opinion of the Court
*588OPINION.
Van Fossan:
The first issue for consideration is whether or not the respondent erred in disallowing for each of the taxable years any deduction on account of contributions which, as stipulated, were of the character specified in section 214 (a) (10) of the Revenue Act of 1924.
*589It appears from the stipulated facts that the decedent’s contributions amounted to $140,000 in 1924 and for the year 1925 were $90,-433.84. In each of those years the amount of decedent’s capital net losses exceeded the amount of her ordinary net income. The respondent computed the deficiency in each year by a…
2Cited by8 opinions
- Smith v. CommissionerUnited States Tax Court · 1970
- Pleasants v. United StatesUnited States Court of Claims · 1938
- Lockhart v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1937
- Fiore v. CommissionerUnited States Tax Court · 1979
- Jacobson v. CommissionerUnited States Tax Court · 1983
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