Peoples-Pittsburgh Trust Co. v. Commissioner
United States Board of Tax Appeals
During 1917 and 1918 the decedent was chief executive officer of Crucible Steel Co. of America. As the executive head of that corporation he signed and made affidavit to its income and excess-profits-tax returns. Subsequently, he was indicted for conspiracy to defraud the United States out of taxes payable by the corporation.
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During 1917 and 1918 the decedent was chief executive officer of Crucible Steel Co. of America. As the executive head of that corporation he signed and made affidavit to its income and excess-profits-tax returns. Subsequently, he was indicted for conspiracy to defraud the United States out of taxes payable by the corporation. He was tried on this charge and acquitted during 1921 and during that year he expended as attorney fees and expenses incident to his defense the amount of $162,048.12. Held that the amount expended constituted ordinary and necessary business expenses deductible from…
1Opinion of the Court
*589OPINION.
Smith :
The issue in this case is whether the amount of $162 048.12 paid out by Herbert DuPuy as fees to attorneys and accountants *590and incidental expenses in connection with defending himself from a criminal charge for conspiracy is deductible in computing his taxable net income for the calendar year 1921. Counsel for petitioners, on brief, after citing numerous decisions of the Board, including several decisions relating to the character of expenses incurred in defending criminal actions, contend that:
The United States of America prosecuted Herbert DuPuy on a charge of conspiring with…
2Cases cited2 opinions
- Kornhauser v. United StatesSupreme Court of the United States · 1928
- Du Puy v. Crucible Steel Co. of AmericaDistrict Court, W.D. Pennsylvania · 1923
3Cited by13 opinions
- Primuth v. CommissionerUnited States Tax Court · 1970
- Carey v. CommissionerUnited States Tax Court · 1971
- Hurt v. CommissionerUnited States Board of Tax Appeals · 1934
- Folker v. JohnsonDistrict Court, D. New York · 1955
- Carey v. CommissionerUnited States Tax Court · 1971
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