Legal Opinion

Firemen's Ins. Co. v. Commissioner

United States Board of Tax Appeals

Decided June 26, 1934No. Docket Nos. 53679, 53680, 56379, 56380, 64419Published

1. Where in prior years a taxpayer deducted and was allowed as an operating expense the entire amount of expenditures made for additions and renewals of furniture and fixtures and the period of limitations has run against the adjustment of the returns for such years, no deduction may be allowed during the taxable year or years on account of depreciation of such property. 2. An amount paid by a corporation to a firm of accountants for services in connection with the…

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1. Where in prior years a taxpayer deducted and was allowed as an operating expense the entire amount of expenditures made for additions and renewals of furniture and fixtures and the period of limitations has run against the adjustment of the returns for such years, no deduction may be allowed during the taxable year or years on account of depreciation of such property. 2. An amount paid by a corporation to a firm of accountants for services in connection with the authorization and issuance of an increase in capital stock is not deductible as an ordinary and necessary expense of carrying on…

1Opinion of the Court

FIREMEN'S INSURANCE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

MECHANICS INSURANCE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Firemen's Ins. Co. v. Commissioner

Docket Nos. 53679, 53680, 56379, 56380, 64419.

United States Board of Tax Appeals

30 B.T.A. 1004; 1934 BTA LEXIS 1230;

June 26, 1934, Promulgated

1. Where in prior years a taxpayer deducted and was allowed as an operating expense the entire amount of expenditures made for additions and renewals of furniture and fixtures and the period of limitations has run against the adjustment of the…

2Cases cited18 opinions

  1. United States v. LudeySupreme Court of the United States · 1927
  2. Holeproof Hosiery Co. v. CommissionerUnited States Board of Tax Appeals · 1928
  3. Emerson Electric Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1926
  4. Giffin v. CommissionerUnited States Board of Tax Appeals · 1930
  5. Firemen's Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1934

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