Murphy v. Commissioner
United States Tax Court
Petitioner husband incurred legal expenses in recovering nontaxable damages solely for personal injuries suffered in an automobile accident which occurred while he was engaged in business. Held, such expenses are nondeductible personal expenses and not business expenses within the meaning of sec. 162.
1Opinion of the Court
Tannenwald, Judge:
Respondent determined a deficiency in petitioners’ Federal income tax for the taxable year 1963 in the amount of $4,983.13. Respondent has conceded one of the two issues raised by his notice of deficiency. The issue that remains for our determination is whether petitioners are entitled to deduct as a business expense under section 1621 a legal fee paid in connection with petitioner husband’s recovery of damages from an automobile accident incurred while he was on a business trip.
FINDINGS OF FACT
Joseph D. Murphy and Irine M. Murphy are husband and wife with their legal…
2Cases cited10 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- United States v. GilmoreSupreme Court of the United States · 1963
- Drill v. CommissionerUnited States Tax Court · 1947
- James Donnelly v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1959
- Mitchell v. CommissionerUnited States Tax Court · 1964
5 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Rafter v. CommissionerUnited States Tax Court · 1973
- Dancer v. CommissionerUnited States Tax Court · 1980
- Stricker v. CommissionerUnited States Tax Court · 1995
- Brennan v. CommissionerUnited States Tax Court · 1971
- Cullen v. CommissionerUnited States Tax Court · 1973
4 more not listed; retrieve them via the Exa API.