Legal Opinion

Jones v. Commissioner

United States Tax Court

Decided September 22, 1954No. Docket No. 43445Unpublished

Non-business expense deductions under section 23(a)(2). - 1. Held, petitioner not entitled to deductions that were by court decree the obligation of a trust, a separate entity. 2. Held, petitioner's litigation expenditures for the protection of a remainder interest in a trust were not for the management, conservation, or maintenance of property held for the production of income. 3. Assuming petitioner's expenditures relating to another trust involved in the same litigation…

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Non-business expense deductions under section 23(a)(2). - 1. Held, petitioner not entitled to deductions that were by court decree the obligation of a trust, a separate entity. 2. Held, petitioner's litigation expenditures for the protection of a remainder interest in a trust were not for the management, conservation, or maintenance of property held for the production of income. 3. Assuming petitioner's expenditures relating to another trust involved in the same litigation were for the management, conservation, or maintenance of property held for the production of income, held, non-deductible…

1Opinion of the Court

Wardwell Jones and Dixie S. Jones, Husband and Wife v. Commissioner.

Jones v. Commissioner

Docket No. 43445.

United States Tax Court

T.C. Memo 1954-157; 1954 Tax Ct. Memo LEXIS 89; 13 T.C.M. (CCH) 882; T.C.M. (RIA) 54263;

September 22, 1954, Filed

Non-business expense deductions under section 23(a)(2). -

1. Held, petitioner not entitled to deductions that were by court decree the obligation of a trust, a separate entity.

2. Held, petitioner's litigation expenditures for the protection of a remainder interest in a trust were not for the management, conservation, or maintenance of property held for the…

2Cases cited4 opinions

  1. Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
  2. Seidler v. CommissionerUnited States Tax Court · 1952
  3. Agnew v. CommissionerUnited States Tax Court · 1951
  4. Coachman v. CommissionerUnited States Tax Court · 1951

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