Bagley v. Commissioner
United States Tax Court
1. Fees paid by petitioner to her attorneys in the taxable year for services and advice with respect to the purchase of tax-anticipatory, interest-bearing bonds, the making of interest-bearing loans to corporate officers for the purpose of protecting petitioner's investment in the corporation, and with respect to the merits and legal aspects of plans submitted to petitioner by a firm of estate planners for the rearrangement and reinvestment of petitioner's entire estate,…
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1. Fees paid by petitioner to her attorneys in the taxable year for services and advice with respect to the purchase of tax-anticipatory, interest-bearing bonds, the making of interest-bearing loans to corporate officers for the purpose of protecting petitioner's investment in the corporation, and with respect to the merits and legal aspects of plans submitted to petitioner by a firm of estate planners for the rearrangement and reinvestment of petitioner's entire estate, held to be deductible nontrade or nonbusiness expenses under section 23 (a) (2), Internal Revenue Code. 2. Attorneys' fees…
1Opinion of the Court
OPINION.
Arundeld, Judge:
We think it clear that the fees paid by petitioner to her attorneys in 1942 for advice with respect to the purchase of tax-anticipatory, interest-bearing bonds and with respect to the making of loans to the officers of Reynolds Tobacco Co. are deductible nontrade or nonbusiness expenses under- section 23 (a) (2) of the code,1 as construed in Bingham's Trust v. Commissioner, 325 U. S. 365. See also Philip D. Armour, 6 T. C. 359. The investment of substantial amounts of accumulated cash in interest-bearing bonds constitutes an act of management of property held for the…
2Cases cited3 opinions
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Mallinckrodt v. CommissionerUnited States Tax Court · 1943
- Williams v. CommissionerUnited States Tax Court · 1944
3Cited by18 opinions
- Luman v. CommissionerUnited States Tax Court · 1982
- Epp v. CommissionerUnited States Tax Court · 1982
- Contini v. CommissionerUnited States Tax Court · 1981
- Cruttenden v. CommissionerUnited States Tax Court · 1978
- Straub v. GrangerDistrict Court, W.D. Pennsylvania · 1956
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