Of Course, Inc. v. Commissioner
United States Tax Court
Petitioner deducted as ordinary and necessary business expenses legal fees incurred in the sale of all of its assets. Said sale occurred during a corporate liquidation coming within the provisions of sec. 337, I.R.C. 1954. An appeal from the decision in this case lies solely to the Fourth Circuit, which has decided that such fees are deductible.
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Petitioner deducted as ordinary and necessary business expenses legal fees incurred in the sale of all of its assets. Said sale occurred during a corporate liquidation coming within the provisions of sec. 337, I.R.C. 1954. An appeal from the decision in this case lies solely to the Fourth Circuit, which has decided that such fees are deductible. Pridemark, Inc. v. Commissioner, 345 F. 2d 35 (C.A. 4, 1965), reversing on this issue 42 T.C. 510 (1964). Held, petitioner is entitled to deduct the legal fees because, even though we disagree with Pridemark, we are obliged to follow its holding.…
1Opinion of the Court
Of Course, Inc. (Formerly: The Isaac Hamburger & Sons Company), a Maryland Corporation in Dissolution, Petitioner v. Commissioner of Internal Revenue, Respondent
Of Course, Inc. v. Commissioner
Docket No. 7961-70
United States Tax Court
59 T.C. 146; 1972 U.S. Tax Ct. LEXIS 34;
October 25, 1972, Filed
Decision will be entered under Rule 50.
Petitioner deducted as ordinary and necessary business expenses legal fees incurred in the sale of all of its assets. Said sale occurred during a corporate liquidation coming within the provisions of sec. 337, I.R.C. 1954. An appeal from the decision in this case…
2Cases cited17 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Woodward v. CommissionerSupreme Court of the United States · 1970
- United States v. Hilton Hotels Corp.Supreme Court of the United States · 1970
- Harrison E. Spangler and Myrtle B. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Spreckels v. CommissionerSupreme Court of the United States · 1942
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