Legal Opinion
L. M. Tracy and Reba A. Tracy v. United States
United States Court of Claims
Decided December 1, 1960No. 356-55PublishedCited by 4 opinions
1Opinion of the Court
DURFEE, Judge.
This is a suit for refund of income taxes based on plaintiffs’ 1 claim that they are entitled to a deduction for the calendar year 1950 of $11,500 in legal fees either as a trade or business expense under section 23(a) (1) (A) of the 1939 Internal Revenue Code, 26 U.S.C.A. § 23 (a) (1) (A), or as a non-trade or non-business expense under section 23(a) (2). 2 The claim has been disallowed by the Commissioner of Internal Revenue and the Government defends this determination on the ground that the expenditures were personal ones which should be considered not deductible under…
2Cases cited12 opinions
- 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
- Lykes v. United StatesSupreme Court of the United States · 1952
- Fred N. Acker v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1958
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3Cited by4 opinions
- M.H. Bell and Bettie Lou Bell v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Walter F. Tellier and Evelyn H. Tellier v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965
- Synanon Church v. CommissionerUnited States Tax Court · 1989
- Walter F. Tellier and Evelyn H. Tellier v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965