Schwartz v. Commissioner
United States Tax Court
Deduction -- Attorney Fees. -- In 1950 petitioner employed attorneys in connection with an examination of his income tax returns for previous years where failure to report all business income and possible fraud was involved. The services of the attorneys were terminated and their fees paid in 1950, which was prior to final determination of additions to tax for fraud and return of an indictment for criminal fraud which resulted in conviction on a plea of nolo contendere.
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Deduction -- Attorney Fees. -- In 1950 petitioner employed attorneys in connection with an examination of his income tax returns for previous years where failure to report all business income and possible fraud was involved. The services of the attorneys were terminated and their fees paid in 1950, which was prior to final determination of additions to tax for fraud and return of an indictment for criminal fraud which resulted in conviction on a plea of nolo contendere. Held, fees deductible in 1950.
1Opinion of the Court
Hymie Schwartz, and His Wife, Jeannette L. Schwartz, Petitioners, v. Commissioner of Internal Revenue, Respondent
Schwartz v. Commissioner
Docket No. 45571
United States Tax Court
22 T.C. 717; 1954 U.S. Tax Ct. LEXIS 150;
June 30, 1954, Filed June 30, 1954, Filed
Decision will be entered for the petitioners.
Deduction -- Attorney Fees. -- In 1950 petitioner employed attorneys in connection with an examination of his income tax returns for previous years where failure to report all business income and possible fraud was involved. The services of the attorneys were terminated and their fees paid in…
2Cases cited4 opinions
- Greene Motor Co. v. CommissionerUnited States Tax Court · 1945
- Loew v. CommissionerUnited States Tax Court · 1946
- Connelly v. CommissionerUnited States Tax Court · 1946
- Schwartz v. CommissionerUnited States Tax Court · 1954