Legal Opinion

Jergens v. Commissioner

United States Tax Court

Decided June 30, 1943No. Docket No. 111757Unpublished

1. Held, the petitioner is taxable on the income of a certain trust, under the provisions of section 22(a) of the Revenue Act of 1938. Andrew Jergens v. Commissioner, 136 Fed.

Read the full summary

1. Held, the petitioner is taxable on the income of a certain trust, under the provisions of section 22(a) of the Revenue Act of 1938. Andrew Jergens v. Commissioner, 136 Fed. (2d) 497 (C.C.A. 5th Cir., June 15, 1943), affirming B.T.A. memorandum opinion entered August 28, 1942, followed. 2. Held, fee paid to investment counsel is deductible as a non-trade or non-business expense, under the provisions of section 121(a)(2) of the Revenue Act of 1942, amending section 23(a), I.R.C., and retroactive to taxable years beginning after December 31, 1938.

1Opinion of the Court

Andrew Jergens v. Commissioner.

Jergens v. Commissioner

Docket No. 111757.

United States Tax Court

1943 Tax Ct. Memo LEXIS 217; 2 T.C.M. (CCH) 385; T.C.M. (RIA) 43322;

June 30, 1943

1. Held, the petitioner is taxable on the income of a certain trust, under the provisions of section 22(a) of the Revenue Act of 1938. Andrew Jergens v. Commissioner, 136 Fed. (2d) 497 (C.C.A. 5th Cir., June 15, 1943), affirming B.T.A. memorandum opinion entered August 28, 1942, followed.

2. Held, fee paid to investment counsel is deductible as a non-trade or non-business expense, under the provisions of section…

2Cases cited2 opinions

  1. Coffey v. CommissionerUnited States Tax Court · 1943
  2. Rosenzweig v. CommissionerUnited States Tax Court · 1942

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API