Legal Opinion
Urquhart v. Commissioner of Internal Revenue, (Two Cases). Urquhart v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided August 24, 1954No. 11246-11248PublishedCited by 19 opinions
1Opinion of the Court
KALODNER, Circuit Judge.
The Tax Court determined that certain litigation expenses were capital in nature. 20 T.C. 944 (September 9, 1953). These appeals followed, the taxpayers contending that the expenses, which were incurred by them in the course of patent litigation, were deductible from income as ordinary and necessary expenses within Section 23(a) (1) or (a) (2) of the Internal Revenue Code. 1
The relevant facts, which are not in dispute, are as follows:
The taxable year involved is 1946. In that year, and since 1939, the taxpayers, -George Gordon Urquhart, Radcliffe M. Urquhart and W. K.…
2Cases cited27 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Kornhauser v. United StatesSupreme Court of the United States · 1928
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
22 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Harrison E. Spangler and Myrtle B. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Livesay Window Company, Inc. v. Livesay Industries, Inc., and Everett G. Livesay Window Company, Inc.Court of Appeals for the Fifth Circuit · 1958
- Industrial Aggregate Company, a Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1960
- Teleservice Company of Wyoming Valley v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Alleghany Corp. v. CommissionerUnited States Tax Court · 1957
14 more not listed; retrieve them via the Exa API.